By using the DriveScore App you are accepting and consenting to the practices described in this Privacy Notice. The data controller of your information is Clear Score Technology Limited of 47 Durham Street, London, United Kingdom, SE11 5JA.
THE INFORMATION WE COLLECT
We collect and process information which:
- you give to us when you register with us, request a car insurance premium quote from third party insurance providers which use your DriveScore as part of their price calculation or otherwise interact with us
- we collect about you or determine about you required for the provision of the DriveScore service, such as your recorded Trips and driving behaviour
- we collect about you or determine about you based on your use of the App
- we receive from other sources, such as third parties who give us information about you
We may collect and process the following data about you:
Information you give us. When you use the DriveScore service or by communicating with us you may give us information. This includes information you provide when you sign up to use the DriveScore service, provide us with feedback, participate in surveys, and when you report a problem.
The information you give us may include:
- Email address
- Date of birth
- Phone number
- Residential details
- Employment details
- Address history
If you also hold a ClearScore account, you may also have provided us with other information when you signed up for that account which we may use or link to your DriveScore account. For further information regarding the information about you which we collect through your ClearScore account, please see the.
Information collected through use of the DriveScore App. In order to provide you with the DriveScore service, the DriveScore App will ask you to enable the collection of additional information after you install the DriveScore app. This includes information:
- collected via your smartphone such as the accelerometer, gyroscope, compass and global positioning system (GPS) readings to determine when you are undertaking a trip in (or on) a vehicle (a " Trip");
- about your Trips, including your global positioning system (GPS) location, the roads you are travelling on, the distance that you travel and the frequency you drive and number of Trips taken with the DriveScore App installed;
- about your driving, including your acceleration and braking, turning corners and speed whilst undertaking a Trip; and
- about your behaviour while undertaking a Trip, including your use of your smartphone during the Trip, the time of day you undertake the Trip and other activity relating to use of the smartphone the DriveScore App is installed on (including Bluetooth connections, Google Activity Recognition status, screen lock status and usage of other smartphone apps to understand whether and how you are using the smartphone that the App is installed on during your Trip.). We do not monitor the content you access or how you use any apps other than the DriveScore App, only whether you use these other apps when undertaking a Trip and the duration of such use.
Information we collect to provide you with our services. In order to provide you with a car insurance premium quote, our third party insurance providers (" Insurers") will need additional information including:
- your driving licence details
- whether you have any licence restrictions or endorsements, including any medical conditions which may be relevant to driving or your insurance, or whether you have any convictions relating to driving
- details about your vehicle, including your vehicle's licence number, age and model of your vehicle, the MOT status of your vehicle and information about where your vehicle is stored
- details of any motor insurance claims you have made in the last 5 years
Some of this information (such as any medical conditions and/or driving offences) is given additional protection under data protection law. We only collect this information where it is necessary for Insurers to provide you with a car insurance premium quote at your request, but we may be legally required to provide it to third parties such as your insurer or law enforcement agencies for other purposes in exceptional circumstances (see 'Who do we share your information with' below for further information).
We may also use the information described above to provide you with other features of the DriveScore service, such as anonymous, aggregated comparisons with other drivers in your area and other insights which might help you to understand your driving behaviour. Unless you are seeking a car insurance premium quote, you do not need to provide us with this information but you will not be able to access certain features of the DriveScore service if you chose not to.
Information we collect about you based on your use of the DriveScore App. Each time you use the DriveScore App, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address, your login information, operating system and platform information about your visit, products you viewed or searched for; response times, errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page
Information we receive from other sources. If you choose to share your information with Insurers, we may receive information about whether or not you have taken out a product with any Insurers, what products you may have used, and other such details about your interaction with Insurers.
Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us (such as emails) but have no access to the calls that you make on your mobile phone unless they are to us.
HOW WE USE THE INFORMATION
We use information we hold about you to provide the DriveScore service to you and to improve the DriveScore service, administer your DriveScore account and communicate with you and, on an anonymous basis, for research, profiling and analytical purposes.
Information collected through use of the DriveScore App. When you install the DriveScore app, and enable the required permissions, the data collected above will be used to develop your "DriveScore"– a score which we calculate based on the information we have collected about your Trips and any specific risk factors we have identified through the Trip data we hold, such as excessive speeding, acceleration, cornering or braking or distraction by your smartphone. We'll also use this information to calculate specific scores for each of these risk factors, as well as a night time driving risk factor and summary statistics such as Trip count and total distance driven.
Your DriveScore will evolve over time as you undertake more Trips using the DriveScore App, so better driving behaviour will improve your DriveScore, while driving practices such as speeding or sharp braking can negatively affect your DriveScore.
Provided that you have enabled appropriate permissions, the DriveScore App will automatically identify when you are undertaking a Trip and will identify when it thinks you are the driver (rather than a passenger). You should review the Trips that the DriveScore App has recorded and reject any Trips recorded where you were not the driver. For the first few Trips you undertake after you install the DriveScore App, and provided you have enabled the appropriate permissions, you will receive a notification from the DriveScore App with details of the Trip the DriveScore App has identified, providing an option for you to reject the Trip if you were not the driver. For subsequent Trips, you will not receive a notification and the DriveScore App will assume that you were the driver based on Trips you have previously rejected, unless you review and reject the Trip in the DriveScore App.
Where you confirm you were not the driver, the data relating to the Trip will not be aggregated with the data of your other confirmed Trips and displayed as part of your DriveScore, although we will retain and use this data as part of our fraud prevention measures.
Once you have undertaken several trips using the DriveScore App, we may give you the option to to request enhanced car insurance quotes. In order to obtain these quotes, your DriveScore Metrics and the personal details we collect from you and other information required to provide a quote will be shared with Insurers on a legitimate interest basis. For further information, see 'Who we may share your data with' below.
We may use the information collected through the DriveScore App to provide you with information about your driving behaviour and how you can improve your driving. As part of the DriveScore service, we may also introduce you to other third parties who offer products and services which may be of interest to you (" Product Providers") based on the data we have collected through the DriveScore App. For example, once the DriveScore App identifies that you have travelled a certain number of miles, we may suggest that the tyres on your vehicle are checked and introduce you to local mechanics or other similar service providers who will be able to provide you with an offer. For further information, see 'Who we may share your data with' below.
We may use anonymised statistical data to improve the DriveScore App, for example, by showing you a comparison of your DriveScore compared to other DriveScore users in your area and may provide this anonymised statistical data to third parties, such as Insurers, for improvement and development of their products and services. However, we will never share information which personally identifies you for these purposes.
Information you give to us or we collect from third parties on your behalf as part of our services. We will use this information to:
- administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, push notification or other electronic means
- verify your identity as part of our identity authentication process
- provide you with information, products and services
- where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you
- notify you about changes to our services
- ensure that content from the DriveScore App is presented in the most effective manner for you and your device
- aggregate it on an anonymous basis with other data for analytical and reporting purposes
- undertake analysis and profiling of your credit information in order to identify and inform you of products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services
- for fraud prevention purposes
Information we collect about you based on your use of the DriveScore App. We will use this information:
- to administer the DriveScore App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
- as part of our efforts to keep our website safe and secure and to prevent fraud
- to make recommendations about products or services that may be of interest
Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.
Recording telephone calls and other communications. We will use telephone recordings or transcripts of your calls with us to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us. We do not have access to the calls made from your mobile phone, unless you're calling us directly.
As with other ClearScore services, we may share your data with other members of our group and with other third parties, such as our service providers, advertisers, Credit Reference Agencies, and Fraud Prevention Agencies and Cybercheck Partners. For more information on each of these third parties and how they may use your data, please see the.
For the data that we collect through the DriveScore App, we share your data with Cambridge Mobile Telematics, who help us to provide the DriveScore App and calculate your DriveScore, and other ClearScore Group Companies to help us provide the DriveScore service.
You can also choose to request an enhanced car insurance quote for which your DriveScore and DriveScore Metrics (as defined at the end of this paragraph) will be shared with Insurers in order to receive a car insurance premium quote (a " Quote"). You can request an enhanced Quote directly through the DriveScore App or Insurers may tell us that you have requested a Quote through other channels (such as their website). In either scenario, Insurers will receive 'snapshots' of your DriveScore Metrics, showing: (i) your score based on Trips recorded within the two weeks prior to your request for the quote; and (ii) your score based on Trips recorded within the 365 days prior to your request for a quote, along with the scores for the each of the risk factors (acceleration, braking, cornering, speeding, phone distraction and night time driving), information about the number of Trips (except where you confirmed you were not the driver) and the distance you travelled used for the purposes of calculating each snapshot. If we do not have two weeks or 365 days' of your Trip history available when you request a Quote, we will share a shorter snapshot of your DriveScore based on the information collected to date. As a fraud prevention measure, we also share snapshots of your two-week and 365-day DriveScore with the Insurers which includes all Trips recorded, including when you have indicated that you are not the driver, which the Insurer may take into account when deciding whether to provide you with a Quote. Taken together, these are your "DriveScore Metrics".
When you want to obtain a Quote from Insurers through the DriveScore App, we will combine your DriveScore Metrics described above with other relevant information we hold about you in your ClearScore account (such as your name and contact details) to enable the Insurers to identify if you are a new or existing customer and so that the Insurer has the information they need in order to provide you with a Quote. You will be provided with the opportunity to review the information that the Insurer receives before it is sent, to ensure it is correct. If the Insurer tells us that you have requested a Quote from them directly or otherwise outside of the DriveScore App, we will only provide the DriveScore Metrics described above and you will be responsible for providing the other information necessary to obtain a quote.
The Insurers may also pass your information to Fraud Prevention Agencies or other third party service providers they work with. Each Insurer will be an independent data controller in relation to your information that they receive from us. We ask Insurers to only use your DriveScore Metrics for the purposes of providing you with a Quote and for any products you choose to purchase, and you can find further information on how Insurers will use the information they receive from us via their own privacy notices.
In order to provide you with information and offers that may be of interest to you through the DriveScore App, we may also provide relevant information we have collected to Product Providers. We will only share limited information with Product Providers so that they can offer services relevant to you, and the information that the Product Provider requires will change depending on the nature of their offering (for example, for a tyre check service, we may share the number of miles driven while using the DriveScore App and your address, so you receive offers within a reasonable distance).
We may also share anonymised, statistical information collected through your interaction with the DriveScore App with Insurers, Product Providers and other third parties so they can understand how DriveScore users are interacting with their offers and services. When we do so, we make sure that these third parties can never identify you individually from the information we provide.
Whilst we never sell your DriveScore data to any third parties, there may be exceptional situations where we are legally required to provide your DriveScore information to another third party, such as a legal request from a law enforcement agency or following a court order. We will only provide your DriveScore information to these third parties where we are legally required to do so.
WHAT IS THE LEGAL BASIS FOR US USING THIS INFORMATION?
We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact our Data Protection Officer.
Our lawful bases may include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you) and our own legitimate interests.
Legitimate Interests. We rely on our own legitimate interests for much of the data processing we undertake when providing the DriveScore service, including the collection of your driving data from your smartphone and using this information to calculate your DriveScore. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of our Insurers, Product Providers or other suppliers, provided that such processing does not outweigh your rights and freedoms. As an example, we may process your personal data to:
- comply with laws that apply to us
- to provide your DriveScore Metrics and personal details to Insurers or other third parties for the purpose of seeking an enhanced Quote; the Insurers will be acting as data controllers which means they are in charge of how they handle your personal data and will have their own legal basis for processing
- display tailored product offers to you
- provide you with our service, including for the purpose of quality control and analysis
- protect you and us from fraud or other threats
- conduct analysis, segmentation and profiling of your data in order to provide you with direct marketing communications (see 'Direct Marketing and How You Can Change Your Preferences' below)
- analyse our users' behaviour and preferences, and information collected from users' devices in order to improve the services we provide to our customers and the user experience on the DriveScore App
- provide anonymised or pseudonymised data or statistical information to third parties to improve their own product and service offerings
- improve our service and manage our customer relationships
If you delete your account, we may also continue to store and where necessary further process information collected prior to the deletion of the account for fraud prevention purposes and for legal and compliance purposes, based on our legitimate interests in protecting our business and our other customers or where we are required to do so by law (for example, if we are required by a court order to disclose your personal data).
Please also note that Insurers and other third parties we may share your data with will act as data controllers for that data they receive. If we cease to process your data for whatever reason, Insurers or third parties may require to continue to hold and process your data for their own purposes and based on their own legitimate interests or other legal basis.
Where we rely on legitimate interests in order to process your data, you may object at any time.
Consent. We are relying on your consent wherever we explicity request your consent to our processing your data. Whenever you have given us your consent , you will be able to withdraw it either by visiting the 'My Account' section and managing your preferences or by deleting your account or deleting the DriveScore App. If you choose to do so we may continue to use the information we collected prior to your withdrawal of consent in anonymised form for our internal business purposes, for analysis and to improve our services based on our legitimate interests described above.
Performance of a contract. We need you to give us the information you provide in order for us to provide you with our services as agreed in ourwith you. As providing recommendations from Product Providers forms part of the DriveScore service, we also rely on the performance of a contract basis in order to provide you with these offers in the DriveScore App.
We cannot provide our services to you, including recommendations about how you can improve your DriveScore, offers from Product Providers or help with any queries you may have, without collecting the information you give us.
DIRECT MARKETING AND HOW YOU CAN CHANGE YOUR PREFERENCE
We offer you the opportunity to receive marketing information from us. You can easily opt-out of receiving marketing from us at any time.
We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods, such as push notifications to your devices.
You may receive the following types of communications from us:
- Product recommendations - we'll get in touch with personalised, timely product recommendations that we believe will be of interest to you. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
- Content communications - we'll send you content such as tips, research, features and news, coaching on how you can improve your DriveScore and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
- Core communications - we will send you a regular DriveScore report, security alerts pertaining to your account, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a DriveScore account and cannot be opted-out of.
If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences here. You cannot unsubscribe from Core Communications. If you do not wish to receive these then you will need to delete your DriveScore account.
You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to:
Data Protection Officer Clear Score Technology Limited 47 Durham Street, London, SE11 5JA United Kingdom
HOW WE PROTECT YOUR INFORMATION
We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data outside of the UK/ European Economic Area, we ensure that appropriate safeguards are in place to protect the data.
All information you provide to us is stored on our secure servers.
We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website or via our apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.
Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. Part of our customer services function is based in India. We have put in place safeguards to protect personal data processed in or accessed from India.
HOW LONG WE KEEP YOUR INFORMATION FOR
While your account remains active, we keep your information for no longer than is necessary depending on the purpose for which we are using it.
How long we keep your information will depend on the purpose for which we use it. While you are a customer of ours, we will only retain your information for as long as is necessary for those purposes.
After termination of your account, we will retain your data for a period of up to seven years after deletion for fraud prevention and legal purposes (for example, if we need to defend ourselves from a legal claim). If you terminate only your DriveScore account, we will continue to retain and process the data we have collected as required for the provision of the other services you continue to receive in accordance with the. We may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defence of a legal claim.
If you follow a link to or from our website or apps to a third party website, please be aware that these websites have their own privacy policies.
Our website and our apps may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
AUTOMATED DECISION MAKING
We use an automated decision making system to make automated decisions based on personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know.
Identity verification. We use an automated decision making system to verify the details you provide against those held by third party providers. If you do not pass the check using the automated system, we cannot provide our services to you without being able to verify your identity. We have processes in place to attempt to verify your identity manually if our automated systems cannot verify you.
Tailored products and services. We may use your information to predict the probability that you may be accepted for a product, or to determine the best order or manner in which to display products to you.
Tailored communications. We want to make sure we're only sending you emails that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving.
You've the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via
DriveScore. We use personal information we collect about you in order to calculate your DriveScore but this information is not used by us to make any automated decisions about you.
If you choose to share your DriveScore with Insurers in order to receive a Quote, the Insurers may use your DriveScore, together with other information about you, to make automated decisions about whether to offer you a Quote and the price of any products you are offered. You can find further information on how Insurers will use the information they receive from us to make automated decisions via their own privacy notices.
You can exercise specific rights with regards to the data that we hold about you.
We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:
Correct your data: you will usually be able to amend any information that we hold about you that is inaccurate or incomplete through the settings in your account.
Request access to your data: you can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law.
Erase your data: you can ask us to delete your personal data where there is no compelling reason for us to keep using it, although we may not be able to continue to provide our services. We may keep your email address to make sure the restriction is respected in future. We also have the right to continue using your information if such usage is necessary for compliance with our legal obligations.
Download your data or send it to another controller: you can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
Object to the use of your data: you can ask that we no longer use your personal data where that use is based on a legitimate interest.
Restrict the use of your data: You have the right to 'block' or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your information, but may not use it further.
Right to withdraw consent: If you have given your consent for us to use your information, you have the right to withdraw your consent at any time. This can be done by contacting our Data Protection Officer.
For the exercise of any of your rights, you can also contact us at.
YOUR RIGHT TO LODGE A COMPLAINT WITH THE ICO
If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact our Data Protection Officer. However, you can make a complaint to the Information Commissioner's Office (ICO) at any time.
Please see the ICO website for further information -