We take your privacy very seriously. We promise that:
We never sell your data, or share it with anyone who doesn't need it as part of your Cuvva experience.
We were tech people before we were insurance people. So our systems are highly secure.
We're committed to transparency. This notice tells you all about how we use your personal data.
We're Cuvva Limited (Cuvva, we, our, us). We're authorised and regulated by the Financial Conduct Authority (FCA) under number 690273. And we're registered with the Information Commissioner's Office under number ZA056769.
We have an independent Data Protection Officer too, they're called Aphaia Ltd. You can contact them at email@example.com, or you can write to them at Aphaia Ltd, Eagle House, 163 City Road, London, EC1V 1NR. It can take a few days to process requests directed to Aphaia, so you might want to send the request to us directly.
Personal data means information which can be used to identify you. We need personal data to see if we can cover you, to calculate your pricing, to help with any claims, and to deliver the best experience.
We see if we can cover you, and calculate your pricing automatically. You can always chat to a human about any automated decision-making in the app. We're available 6am-1am, everyday.
As with all insurance, working out your pricing requires profiling. This means your pricing will be influenced by things like your age, job and location at the time of your quote.
We'll collect anything we need via the app, our website, relevant third parties, and any other interactions you might have with us. There's more detail on the information we ask for here.
To help us provide better customer support, we may record the type of device or browser you use. This can include the model, operating system, software, and language.
You can control our ability to use device advertising identifiers in your device's settings. If you give us your permission, we may use device advertising identifiers to see how you found us. This could let us know which of our ads you saw before downloading our app (like a Facebook ad, or whether you found us via a Google search).
If you need any guidance on your device's settings, just let us know and we'll be happy to help.
Our conversations (including chats, emails and phone calls) may be recorded or monitored to provide an audit trail. We may use them to help train the Cuvva team, too.
To help us provide better customer support, we may gather access information when you use our services. This can include IP addresses, access dates and times, system activity including app malfunction or screens viewed.
Once you've entered your driving licence details and agreed to the Fair Obtaining Notice, we may collect information about your driving licence and history from the DVLA, MyLicence or other relevant entities. We need this so we can offer motor insurance products to you.
Photo ID and selfie
We may require your consent to compare a selfie you provide with the photo in your ID by biometric means and through the help of AI. This is to positively authenticate you, in line with anti-money laundering regulations. If you are unhappy with the result of the comparison, you may reupload the photos or request to have the photos checked again with the assistance of human intervention. Your later withdrawal of consent will not affect the validity of the check made prior to the withdrawal. If you do not consent or withdraw previously given consent, your ability to use our services will be limited as processing your biometric data is necessary for us to verify your identity and decide whether you can purchase our policies.
We may also use automated systems using AI to check the quality of the photo ID you upload and train the AI using the pseudonymised photo ID for improvement purposes. If you are unhappy with the result of the check, you may reupload the photos or request to have the photos checked again with the assistance of human intervention. Where we deem appropriate, we may as part of this additional check ask you for other means of identification.
Before we collect any location, motion or telematics data, your device will ask for your consent.
We need your location to offer you a quote. It helps us prevent misuse, and lets us know you're purchasing from the right place - bearing in mind you can only purchase our products while you're in the UK. Your location can be used to determine risk, and will be recorded on your profile.
We may use motion and telematics data to see if we can cover you, to determine accurately when you're driving, to work out your pricing, and to help with any disputes or claims. You may be able to get better pricing if the data shows that you're a good driver.
We won't use your location, motion or telematics data for anything we haven't listed above. You can change your consent at any time from your device's settings. But your ability to use us will be limited if we can't access the data we need.
We may collect data on quotes, pricing and claims. This can help to improve our pricing, our processes and those of the relevant insurer, to help with risk modelling, and to help with the detection and prevention of fraud.
Your personal data belongs to you. Any quote, pricing or claims data that isn't your personal data belongs to us. In some cases, we'll anonymise information so that it can no longer be used to identify you.
Depending on the cover you're looking for, we might carry out a soft credit check using your details. We'll only do that when we need to, to see if we can cover you.
This means we take into account your credit score, number of judgements against you (if any), reported insurance policy history, claims data and whether you're on the electoral roll. This information won't be readily available to members of the Cuvva team. But our systems will check the data as part of the quoting process.
Soft credit checks don't leave a visible footprint on your credit file. You can see them on your own credit file, but lenders can't.
If you use our Car Sharing feature to lend your vehicle or to borrow another Cuvva user’s vehicle, you may need to provide your bank account details, including account name, account number and sort code.
We need this information so that we can process payments which vehicle borrowers wish to make to vehicle lenders, and to take any Cuvva fee for providing our Car Sharing service. This information will be available to a small number of Cuvva employees (such as our Finance team) and third party payment processing and account provider services in order to process your paying or receiving of Car Sharing payments.
Vehicle registration mark (number plate)
We may ask you to submit a photo of your vehicle for vehicle identification. Please note the photo needs to be of sufficient quality, which will primarily be checked by our automated systems using artificial intelligence (AI) but human intervention will be involved where we consider it necessary.
We may use publicly available information, or information in plain view, to prevent misuse. For example, if we see information which shows a vehicle driving dangerously, we may decide to ban that vehicle and/or the driver. We don't systematically browse publicly available information to compare it with our user information.
Personal data for Car Sharing and User-Generated Content (UGC)
We may collect and share your personal data through our Car Sharing feature (please refer to clause 11 in our Terms and Conditions for more details about this feature) for the purposes of facilitating the lending or borrowing of a vehicle. You may also voluntarily share your own personal data through our Car Sharing feature for similar purposes. Personal data you might decide to share could include your name, ownership status of the car, preferred pick up or drop off location, profile photo and vehicle photo. We refer to any content contributed by you to our app which is visible to at least a subset of the app’s users as “User-Generated Content” or “UGC”.
This personal data and UGC will be visible to third parties who have indicated that they may wish to lend or borrow a vehicle. We will process any such personal data for the purposes of enhancing our Car Sharing feature.
We love feedback. So much so that we occasionally invite people to Cuvva HQ, or another agreed location, to find out their views. This will include the use of personal data which will be made clear to the people involved beforehand, with their consent. If consent is withdrawn, we may continue to process the data in anonymised form.
If you've given us feedback via our website, the app, or by chatting with us; first of all, thank you! We might email you with an update on the action we've taken following your feedback.
We also really appreciate it when Cuvva users review us online. We may re-publish said reviews, along with your first name if that was included in your review.
Children (individuals under 18) have the same rights as adults over their personal data. If you're under 18 and would like to use our service, remember you can ask us any questions in the app.
If you choose to connect your Cuvva account with a third party, like Facebook for example, we may ask for access to information held by the third party. They will allow you to consent or deny access, and you can control this via their services.
Be aware of the privacy notices of any third party service you use, even if you have reached that service through a link from Cuvva.
If you choose to share someone's information with us, it's your responsibility to ensure they consent or someone with parental responsibility for them consents.
If you use Cuvva with a car which belongs to, or is registered to, someone else, we may share your policy information with them - including the legal documents.
We may share our data on your quotes, price, location, telematics, claims and other information with our underwriters and third party providers (such as telematics service providers). This will include your personal data where necessary (such as where personal data is needed to arrange, administer and underwrite your policy). We'll anonymise your personal data where practicable.
We use third-party fraud detection providers that combine data of various claims using artificial intelligence and machine learning. This helps us to fight fraud and keep our pricing competitive.
We use third party payment processing and account service providers to facilitate our Car Sharing features.
The data we collect from you may be transferred to and stored somewhere outside the European Economic Area ("EEA"). It may be processed by staff outside the EEA who work for us or one of our suppliers.
Where the data is sent outside the EU/EEA, the protection may be based on standard clauses verified by the European Commission and other data security safeguards. Or there might be an adequacy decision in place guaranteeing an equivalent degree of data protection.
The parties we send your information to are obliged to comply with data protection laws, regulations and standards. Each of them signs a contract with Cuvva, giving assurances over the security and correct treatment of your information.
You can find out more on where your information goes here.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing your various information as set out above are: (a) Your consent.
Where we rely on your consent to process your data, you’re able to remove your consent at any time. If you'd like to withdraw your consent, you can just let us know, or in the case of location, motion and telematics data, change your device setting.
However, your ability to use us may be limited if we can’t access certain data.
(b) Our legitimate interest. We need to process your information to:
Determine if we can cover you;
Calculate your pricing;
Help with any claims;
Provide better customer support;
Process payments for Car Sharing features;
Provide and improve our services in general;
Enhance or facilitate better use of the Car Sharing feature; and
Prevent Harmful Behaviours (as defined in clause 11 of our Terms and Conditions);
We'll keep your information only for as long as there's a need to. This includes retaining your personal data to:
Respond to any questions, complaints or claims made by you or on your behalf;
Detect and prevent misuse and fraud;
Show that we treated you fairly;
Keep records required by law;
Account for various limitation periods in law; and
Allow it to be used in any court proceedings arising out of or in connection with you, your vehicle or your policy.
If you're a customer and you've bought a Cuvva policy, we need to keep your data for at least seven years from when your most recent policy expired, or for at least seven years from when any claim made under your policy was finally decided or settled, whichever is later.
Where you have used our Car Sharing feature and provided bank account information, we will typically only keep your bank account number for up to 30 days, unless we have a legitimate reason to keep it longer.
We need to keep it for that period of time in case of any claims against you, any disputes, or anything else meaning we need to show records of your cover. As an example, someone could make a claim against you some time after you took your policy out. Being able to refer to your records can help to defend against claims.
If the above doesn't apply, we may be able to delete your account upon your request. There's more information on that below.
If any of the above does apply, we will delete your information after the lapse of the appropriate period upon your request. This will mean that all of your data is removed from our live systems. Your data will still exist in our archive. But we will have marked your records so that they appear to have never existed.
Whether or not you request deletion of your own personal data, we will delete your personal data from our live systems if, after an appropriate period of time, we determine it’s no longer necessary to retain your personal data, after considering the factors listed in the first paragraph of this section.
Cuvva and its databases operate within the Amazon Web Services and Google Cloud. Their computers are housed in secure data centres with heavily restricted access, and numerous levels of security, to keep your data safe.
Your personal data is stored securely behind two factor authentication. We hold all data on isolated networks, transmit data fully encrypted, and isolate sensitive data from other areas of our system.
We arrange independent and expert penetration testing on our systems, which helps us maintain first-class information security.
If you'd like us to delete your information, just let us know. Again, the best way to do that is usually via the app.
Bear in mind that if you've bought a policy with us, we may not be able to delete your account when you ask. We need to keep your data for at least seven years from when your most recent policy expired. That's in case of any future claims against you, any disputes, or anything else meaning we need to show records of your cover.
There may be other reasons why we won't be able to delete your account where you haven't bought a policy; for example any disputes, or for the detection and prevention of fraud.
In other cases and wherever we can, we'll delete your account upon your request. This will mean that all of your data is removed from our live systems. Your data will still exist in our archive. But we will have marked your records so that they appear to have never existed.
You have the right to object to the processing of your data in certain circumstances. For example, you have the right to stop your data being used for direct marketing. We don't send many marketing emails. But if you've opted in to our updates and change your mind - you can unsubscribe at any time.
You have a right to get a copy of the personal data we hold about you or to ask us to transfer that personal data to another organisation. We'll provide or transfer your data in a standard portable format. If you have any trouble understanding the data, let us know and we'll help. The best way to ask is usually via the app.
We won't usually charge a fee for providing or transferring that information, but we may do in certain circumstances. For example, if you make repetitive requests for information, we may charge a small fee or refuse your request.
You can login to the app to correct any inaccuracies in parts of your account. Some information can only be updated by our support team - so please speak to us if you'd like any help. Changing information on your account could impact your pricing, and it could mean that we're no longer able to offer you one or more of our products.
You have a right to restrict the processing of your personal data in certain circumstances. This means you can limit the way we use your data.
This is an alternative to requesting the erasure of your data. For example, we could securely and temporarily store your data in another system if you contest its accuracy and we need to verify it.
We keep our privacy notice under regular review, and we'll tell you when we make material updates - by email or by notifying you in the app or our website. We regularly make small changes, so we suggest that you check the latest notice now and then.
Please get in touch if you have any questions, and we'll do our best to help. The best way to speak with us is usually in the app. Otherwise, you can email us at firstname.lastname@example.org, or write to us at Cuvva, Ground Floor, Old Sorting House, 46 Essex Road, London, N1 8LN.
If you've made a complaint and you're unhappy with our reply, you're entitled to speak with the ICO:
ICO website: https://ico.org.uk/concerns
ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113