1.

Introduction

This Privacy Statement will help You understand how We collect, use and protect Your personal information when You interact with Us. Please take a few moments to read the sections below and learn how We may use Your personal information. You should also show this notice to anyone else who may be insured to drive under Your policy. You acknowledge that by providing Your personal information to Us, You consent in its processing in accordance with this Privacy Statement. We are unable to offer You any insurance product unless You provide explicit consent for the collection and use of such sensitive data as defined in the Data Protection Act 1998.

If you have a Bell policy, please also read the Bell - additional privacy and security information.

2.

Collecting Information

Personal

When providing information about others who may be insured You confirm that You have the consent of these individuals to supply their personal information

We will collect Your personal information when:

  • You ask for a quote
  • You purchase our products and services
  • You make customer enquiries
  • You register for information or other services
  • You register a claim
  • You respond to communications or surveys

The type of personal information We may collect could include:

  • Name and address, date of birth and gender
  • Telephone numbers and email address
  • Credit/debit card details
  • Lifestyle and other information
  • We may also collect information defined as "sensitive data" within the Data Protection Act 1998. This includes:
    • Medical history
    • Claims history
    • Criminal convictions etc.

We may also monitor or record calls, emails, SMS messages or other communications in accordance with UK law, and in particular for:

  • Business purposes such as quality control and training
  • Processing necessary for entering into or performance of a contract
  • Prevention of unauthorised use of our telecommunication systems and websites
  • Ensuring effective systems operation
  • Meeting any legal obligation
  • Protecting Your vital interests
  • Prevention or detection of crime
  • For the legitimate interests of the data controller

Please visit www.ico.gov.uk for further information.

All personal information will be held in the strictest confidence and used only for the purposes for which We collect it. If You would like Us to remove any personal information from our records, then please write to Us at our Customer Services Department, Capital Tower, Greyfriars Road, Cardiff CF10 3AZ. We will make all reasonable efforts to delete Your information from our files if it is deemed appropriate.

Non-personal information collected online

Cookies

If You would like information regarding cookies or our use of them, please read our online Cookie policy at bell.co.uk.

3.

How Your information will be used

General

We will use Your information for:

  • Processing Your quotes
  • Administering Your policy including claims handling
  • Fraud prevention and detection
  • Credit scoring or other automated decision-making systems
  • Administering debt recoveries
  • Verifying Your identity when required
  • Undertaking market research and statistical purposes
  • Keeping You informed about promotions and new developments by email, telephone or post

Dealing with Other People

Policy Administration (with the exception of General Condition 4 - Cancellation).

It is our policy to deal with Your spouse, partner or parent and any other person who is named on Your policy. If You would like someone else to deal with Your policy on Your behalf on a regular basis please let Us know.

Claim Process

To ensure an efficient and speedy claim process We will take instruction from You or any other person provided they are named on the policy. If You would like someone else to deal with Your claim on Your behalf please let Us know.

If You give Us information about another person, in doing so You confirm that they have given You permission to provide it to Us to be able to process their personal data (including any sensitive personal data) and also that You have told them who We are and what We will use their data for, as set out in this Statement.

Marketing

EUI Limited will contact You from time to time by telephone, post, email or SMS to keep You informed with news, products or services, including but not limited to car insurance (e.g. other automotive or financial products, or other carefully selected offers or promotions which We feel may be of interest to You). If you have visited our site and have selected to view a quote, we may contact you, by telephone, to discuss your quote and the cover options available to you.

Other carefully selected companies may also contact You by post. If You have opted in to receive emails, SMS or telephone calls from other selected companies, You may also be contacted about other products that We believe may be of interest to You by these contact methods.

If You do not want Your personal information to be used this way, please click here or write to the Marketing Department, EUI Limited, Capital Tower, Greyfriars Road, Cardiff, CF10 3AZ, who will ensure that Your information is not used for these purposes.

At renewal

In order to offer You continuous cover on Your policy, EUI Limited will arrange for Your policy to be automatically renewed. You should be aware that We can only guarantee automatic renewal when:

  • You have made Us aware of any changes to Your policy details
  • The credit/debit card details have not changed
  • The credit/debit card holder has given their explicit consent to his or her card being charged at renewal

Unless We hear to the contrary, EUI Limited is entitled to assume at renewal that Your details have not changed and You have the consent of the card holder.

If You wish to make changes to Your policy then, unless You inform Us otherwise, EUI Limited will charge the payment details (card or bank account) held on record for any additional amount due.

You may inform Us of any changes or opt out of automatic renewal at any time by contacting our Customer Service department. We will also contact You with a reminder that Your insurance is due for renewal.

4.

Confidentiality

We will endeavour to treat Your personal information as private and confidential.

We would like to bring to Your attention our obligations to disclose information in the following four exceptional cases permitted by law, and the other situations set out below. These are:

  • Where We are legally compelled to do so
  • Where there is a duty to the public to disclose
  • Where disclosure is required to protect our interest
  • Where disclosure is made at Your request or with Your consent

Also, from time to time We will employ agents and subcontractors to process Your personal information on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.

If You make a complaint about the service We have provided, We may be obliged to forward details about Your complaint, including Your personal information, to the relevant ombudsman. You can be assured that they are similarly obliged to adhere to the Data Protection Act and keep Your personal information strictly confidential. In the unfortunate event that You have to make a claim then We will need to disclose information with any other party involved in that claim. This may include:

  • Third parties involved with the claim, their insurer, solicitor or representative
  • Medical teams, the police or other investigators

Credit Reference

When You apply to Us to open an account, We make a number of checks to assess Your application for credit and verifying identities to prevent and detect crime and money laundering. To obtain this information, We will check the following records about You and anyone else who may also be insured and whose personal details have been provided as part of the insurance application.

  • Our own records
  • Credit Reference Agency (CRA) records. When We search these records CRAs will place a search footprint on Your credit file that may be seen by other lenders. They supply Us with both public (including the electoral register), and shared credit and fraud prevention information
  • Fraud Prevention Agency (FPA) Records

We make searches about You at credit reference agencies who will supply Us with information, including the Electoral Register and credit information. The agencies will record details of the search whether or not Your application proceeds. The searches will not be seen or used by lenders to assess Your ability to obtain credit. We may use scoring methods to assess this application and to verify Your identity. Credit searches and other information which is provided to Us and/or the credit reference agencies, about You and those with whom You are linked financially, may be used by EUI Limited and other companies if You, or other members of Your household, apply for other facilities including insurance applications and claims. This information may also be used for debt tracing and the prevention of money laundering as well as the management of Your account. Alternatively, We may ask You to provide physical forms of identification.

We may also make periodic searches at CRAs and FPAs to manage Your account with Us.

Information on applications will be sent to and recorded by CRAs. When You borrow from Us, We will give details of Your account(s) and how You manage it/them to CRAs. If You borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks, and to trace Your whereabouts and recover debts that You owe. Records remain on file for six years after they are closed, whether settled by You or defaulted.

If You give Us false or inaccurate information and We suspect or identify fraud, We will record it and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.

If You borrow from Us and do not make payments that You owe Us, We will trace Your whereabouts and recover debts.

Your data may also be used for other purposes for which You give Your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

How to Find Out More

This is a condensed guide to the use of Your personal information. If You would like to read the full details of how Your data may be used please phone our Customer Services Department on 0871 882 1100, (Calls to 0871 numbers are charged at 8p per minute plus network extras), or write to Us at Pricing Department, Floor 23, Capital Tower, Greyfriars Road, Cardiff, CF10 3AZ.

You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge You a small statutory fee.

  • Call Credit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk.
  • Equifax, Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US or call 0844 335 0550 or log on to www.equifax.co.uk.
  • Experian, Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF or call 0844 481 8000 or log on to www.experian.co.uk.

Please contact Us on 0800 052 3144 if You want to receive details of the relevant fraud prevention agencies.

If necessary We may also have to investigate Your claims and conviction history in the course of administering the claim. You can be assured that We will keep such investigations strictly confidential.

Insurers pass information to the Claims Underwriting and Exchange Register, run by Insurance Database Services (IDS) and the Motor Insurance Anti-Fraud and Theft Register, run by the Association of British Insurers (ABI). This helps insurers check information and prevent fraudulent claims. When We deal with Your request for insurance We may search these registers. Under the conditions of Your policy, You must tell Us about any incident (such as an accident or theft) which may give rise to a claim. When You tell Us about an incident We will pass information to the Registers.

Information relating to Your insurance policy will be added to the Motor Insurance Database ("MID") managed by the Motor Insurers’ Bureau ("MIB"). 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:

  1. Electronic Licensing
  2. Continuous Insurance Enforcement;
  3. Law enforcement (prevention, detection, apprehension and or prosecution of offenders)
  4. 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 vital that the MID holds Your correct registration number. If it is incorrectly shown on the MID You are at risk of having Your vehicle seized by the Police. You can check that Your correct registration number details are shown on the MID at www.askmid.com.

Fraud prevention and detection notice

In order to prevent and detect fraud insurers may, at any time:

  • share information about You with our other group companies
  • pass details to Insurance Hunter, a central insurance application and claims checking system, whereby it may be checked against information held by Insurance Hunter and shared with other insurers

If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies.

Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • checking details on applications for credit and credit related or other facilities
  • managing credit and credit related accounts or facilities
  • recovering debt
  • checking details on proposals and claims for all types of insurance
  • checking details of job applicants and employees

Please contact Us on 0800 052 3144 if You want to receive details of the relevant fraud prevention agencies.

We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.

We may also disclose information about You and Your policy:

  • To companies within the Admiral Group (For the purposes of this Privacy Statement, "Admiral Group" means Admiral Group plc and any company or entity in which Admiral Group plc owns more than 15% of the issued share capital. Companies in the Admiral Group shall include, without limitation, EUI Limited, Admiral Insurance Company Ltd, Admiral Insurance (Gibraltar) Ltd, Inspop.com Ltd, Able Insurance Services Ltd and any other company that is incorporated within the Admiral Group at any time in the future)
  • In the event that We undergo re-organisation or are sold to a third party, in which case You agree that any personal information We hold about You may be transferred to that re-organised entity or third party
  • Where it is necessary to deliver the products and services bought by You. For example, We may disclose Your personal information to a credit card company to validate Your credit card details and obtain payment. It may also be necessary for Us to pass Your personal information to the organisation from whom You have ordered any products or services other than Your EUI Limited insurance product, such as a travel insurance or a personal accident cover provider, etc. At all times, EUI Limited will remain the Data Controller unless We inform You otherwise

5.

Information Security

On our websites We protect any information You have given Us by providing You with a User ID and password. We also use industry standard secure sockets layer (SSL) 128 bit encryption technology to encrypt sensitive information in transit to our servers.

The User ID and password helps Us to protect Your personal information. You may need a User ID and password to access Your personal information on our website. You must keep this password safe and must not disclose it to anyone. We will accept no responsibility or liability if a third party obtains and uses Your User ID and password. You must tell Us immediately if You have lost Your User ID or password, or if You believe a third party may have obtained it. Please also tell Us if You would like Us to change Your User ID or password for any reason.

When You ask for a quote from Us, We will process the data on a secure server. Microsoft Internet Explorer and Netscape Navigator will confirm that You are in a secure area by displaying an unbroken key or lock in the bottom right hand corner of Your browser window.

Some organisations have a security feature called a firewall to protect their computer systems. These firewalls may prevent You from connecting to our secure server to get a quote. If You are at work and cannot connect to our site, please speak to Your IT administrator to learn more.

Please be aware that communications over the Internet, such as emails or webmails, are not secure unless they have been encrypted.

Your communications may route through a number of countries before being delivered - this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

It may be necessary to transfer Your personal information to other Group companies or service providers located outside of the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those in the UK or the EEA - in these instances We will take steps to ensure that Your privacy rights are respected.

6.

Access to Your information

You can write to Us at any time to obtain details of the personal information that We may hold about You. Please write to the Data Protection Officer, EUI Limited, Capital Tower, Greyfriars Road, Cardiff CF10 3AZ. Please provide Your name, address and policy number and tell Us what information You would like.

We will take all reasonable steps to confirm Your identity before providing You with details of any personal information We may hold about You. Please provide two forms of identification such as a copy of a driving licence, passport, or document containing Your signature, and a copy of a recent utility bill that confirms Your address.

In accordance with the Data Protection Act 1998, We are entitled to charge £10 to cover the administration costs. Please make cheques payable to "EUI Limited".

7.

Privacy Support

We reserve the right to amend or modify this Privacy Statement at any time and in response to changes in applicable law.

The Data Controller is EUI Limited (registered number 02686904). Admiral, Bell, Diamond and elephant.co.uk are trading names of EUI Limited. At all times EUI Limited will remain the ultimate data controller. In this Privacy Statement "We", "Us" and "our" means EUI Limited.

If You have any enquiry about our data protection and privacy practices, please write to the Data Protection Officer as above.

Bell - additional privacy and security information

IMPORTANT

It is important that You notify any authorised person that drives Your vehicle that a Telematic Unit has been installed and that their journey will be monitored and data collected.

Also, if You give us information about another person, in doing so You confirm that they have given You permission to provide it to us to be able to process their personal data (including any sensitive personal data), and also that You have told them who We are and what We will use their data for.

Who We are & how We will use Your information

For the purpose of the Data Protection Act 1998, the data controllers for any personal data You supply or that is recorded by the Telematic Unit are EUI Limited and Octo Telematics S.p.A.

Bell is a trading name of EUI Limited.

We, EUI Limited and Octo Telematics S.p.A and any appointed agents and/or service partners, will process Your information in accordance their respective responsibilities under the Data Protection Act 1998 and any applicable UK and EEA legislation. To protect Your information captured by the Telematic Unit, it will be transmitted in a secure format. From the installation, We will use the Telematic Unit to capture data from Your vehicle relating to the date, time, speed, location and other associated vehicle information.

We will gather data from Your vehicle to enable us to:

  • Test Your Telematic Unit (e.g. during installation)
  • Provide You with an insurance premium based upon Your driving performance
  • Provide You with any additional optional Telematic services that are or may become available, where You agree to these at purchase or during the lifetime of Your policy.

Third Parties

Telematic data will only be disclosed to other parties in the following circumstances:

  • To our agents and subcontractors for operational reasons, including providing the agreed services under the policy
  • If We are required by law to disclose the information, such as to our regulators or if We are issued with a court order
  • To Octo S.p.A, as detailed below

EUI Ltd, Octo, and those acting for both companies, will use the data captured by the Telematic Unit for the purposes of:

  • Calculating and charging insurance premiums based upon actual vehicle usage, and compiling and generating Driving Scores
  • Controlling Your personal data for the purpose of providing You with services relating to the insurance policy. We will process Your information in accordance with our responsibilities under the Data Protection Act 1998 and European Data Protection Directive
  • Carrying out the installation, activation, deinstallation, disconnection, servicing, updating or testing of the Telematic Unit
  • General research and analysis, mapping purposes, researching and refining techniques for analysing motor Telematics data and the supply of traffic information. In all such circumstances the information will be used anonymously and will not identify any individual, vehicle user, or the policyholder
  • Enabling EUI Ltd, Octo and any service partners, to contact You by post, electronic mail, telephone or text messaging regarding the administration of Your insurance policy and the associated services
  • Provision of the insurance services under the policy, including management of claims, underwriting and policy servicing. Data will be used for any underwriting or claims development or investigations that may be required, and for fraud prevention, detection and investigation purposes

Your information may also be shared with the relevant insurance and claims databases, in accordance with the Privacy Policy, shown above.

Version 03/13