MOBILE APPLICATION PRIVACY POLICY

CLAIMS MADE EASY

Please Read This Policy Carefully

Insure Apps Technology Limited, a company registered in Scotland (Company No. SC556846) and the owner of “Claims Made Easy” App ( we ) are committed to protecting and respecting your privacy.

This policy (together with our End-user Licence Agreement (EULA) and any additional terms of use incorporated by reference into these documents, together our Terms of Use) applies to your use of:

• Claims Made Easy mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the documentation and services accessible through the App ( Services), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Legal Basis For Processing Your Personal Data

We require your consent to collect and process your data. To register as a user with the App and use the Services you must consent to us using your data for the purposes detailed in this policy. 

If you do not provide us with consent to use your data outlined in this policy, you will not be able to register as a user with the App and/or use the Services.

You may withdraw your consent at any time by contacting [email protected]. However if you do, this means you will no longer be able to use the App and/or the Services.

We Are Your Data Controller

For the purpose of Data Protection Law, we are the data controller.  

Any reference to the Data Protection Law includes the Data Protection Act 1998 and all applicable laws and regulations relating to the processing of personal data and privacy from time to time, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other applicable supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction.  For the avoidance of doubt this also includes, from implementation, the General Data Protection Regulation (“Data Protection Law”), which is due to become effective in the UK on 25th May 2018.

Information We Collect From You

We will collect and process the following data about you:

• Information you give us (Submitted information): This is information you give us about you by filling in forms on the App, or by corresponding with us e.g. reporting a problem. It includes information you provide when you download or register with the App, subscribe to any of our Services or submit an insurance claim report.
  
  The information you give us may include your name, gender, address, Date of Birth, age, e-mail address, health or injury information, phone number, username and other registration information, date you passed your driving test, photograph of your driving licence, car registration number, insurance cover details, details of any other people injured, details of the other party’s vehicle, details of witnesses or details of police officers attending any incident relating to any insurance claim.
  
  By providing us with any third party details you are confirming that you have obtained their consent to share their data with us.
   
• Information we collect about you and your device. Each time you use our Apps we will automatically collect the following information:
  • details of your use of our App; and
  • Location information. We use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting us at: [email protected] or changing your location settings on your device. However, in such cases you may need to manually insert location data into the App.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Submitted Information:
  
  (i)  to provide the Services as advertised which includes the collection of data (including personal data) relevant to incidents forming the basis of (or connected to) insurance claims. Data will be passed on to your employer, their insurance broker and in some circumstances, the insurance company providing your employer’s insurance policy, for the purposes of dealing with the insurance claim. 
  
  (ii) We may also use your details to send you emails telling you about any service updates and/or to ascertain your opinion on how your claim was handled.
  
  (iii) Provided you have given us your consent, we may send you marketing communication by email, text, telephone or post informing you about our goods and services or, goods and services of a third party which we think may be relevant to you.  You can withdraw consent to receiving such communications at any time by contacting [email protected] . 
   
• Location information: the location of your accident will be passed on to your employer and their brokers for the purposes of dealing with the claim but also so that we can establish accident blackspots.
• We may anonymise your information and combine it with other anonymised data to create information, statistics and research relating to insurance claims and the incidents that form the basis of insurance claims.  All data will be anonymised and you will not be identifiable from any work we create. 

Disclosure of your information

We will disclose the data we collect from you to the following third parties:

Category of data	Recipient	Purpose
Submitted Information	Insurance Broker/Insurance Firm	Processing claim
Submitted Information	Employer	Processing claim
Location Information	Insurance Broker/Insurance Firm	Processing claim
Location Information	Employer	Processing claim

You agree that we have the right to disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

In addition, we may disclose your personal information to third parties:

• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets. It is likely however that in such circumstance we shall anonymise all personal data as far as possible before disclosing the same to a prospective seller or buyer.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:

• enforce or apply the EULA, and other agreements you have agreed to with us or to investigate potential breaches; or
• protect the rights, property or safety of Insure Apps Technology Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We Store Your Personal Data

All information you provide to us is stored on secure servers in Ireland. Your information will not be passed outwith the EEA. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How Long We Will Keep Your Data For

Part of the purpose of the App and the Services is to collect data (including personal data) relevant to incidents forming the basis of (or connected to) insurance claims, with a view to making the claim process more efficient and cost effective.  Each insurance policy will specify the time period in which claims must be intimated to the insurer following the incident giving rise to the claim (or once the insured becomes aware of the incident giving rise to the claim) (“the Limitation Period”). We will store your data for this Limitation Period.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; 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, such as using secure URLs and a reputable partner for hosting your personal data.

YOUR RIGHTS

You have the following rights:

• You can withdraw your consent to us processing your data for use with the App at any time by contacting us at: [email protected] .  Please note that if you do this you will no longer be able to use the App or the Service.
• You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by refraining from checking certain consent boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: [email protected] or by following instructions on each marketing material.
• You have the right to lodge a complaint with the Information Commissioners Office (ICO) if you think that we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: https://ico.org.uk/.
• You have the right to access information held about you. You can access your personal data and correct, update or delete it by accessing the App and making any amendments as necessary.   Otherwise you can contact [email protected]
• In certain circumstances you have the right to ask us to provide you with your information in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. More information can be found at https://ico.org.uk
• In certain circumstances you have the right to object to us processing your data which involves using your data for automatic decision (including profiling) purposes. More information can be found at https://ico.org.uk

Third Party Links

The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Changes To Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on the App and, where appropriate, notified to you when you next start the App or log onto one of the Services. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: [email protected].