Purpose

This privacy notice aims to give you information about how Rapid Vehicle Management collects and processes your personal data as a customer, and/or through your use of this website, in accordance with the Data Protection Act 2018 and the United Kingdom General Data Protection Regulation. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller/Processor

Rapid Vehicle Management acts as the Data Controller registered with the Information Commissioner’s Officer (ICO) with registration number ZA323622. We are responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise any of the legal rights detailed in section 10, please contact our Data Protection team using the details set out below.

Contact details

Registered address:
The Lighthouse, 98 Liverpool Road, Formby, Merseyside, L37 6BS

Trading address:
Unit F1, Imperial Business Estate, West Mill, Gravesend, Kent, DA11 0DL

Email address: [email protected]

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please also be aware that we are not responsible for the security or content of these external sites or services. Accessing them is at your own risk and subject to their respective terms and policies.

What this means

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes bank account, credit history and payment card details.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9. Policy Data includes information on quotes, vehicle(s) / property, your current policy as well as lapsed and cancelled policies you might have had with us.
10. Claims Data includes information about non-fault and fault claims you have made with us and other insurers. This includes data sent to us by 3rd parties where we act as a controller.
11. Telematics Data includes information collected on your location, mileage, speed related data, date/time, data that indicates commercial use, overnight parking, journey data and other driving characteristics as part of any policy that you purchase from us that requires you to have a telematics tracking device installed.
12. Vulnerability Data includes information on any characteristics of vulnerability that you disclose to us, which enables us to provide the appropriate level of support your circumstances dictate. This may include Health Data which is defined as Special Category data (see below). We also limit the data retained on our systems in line with best practice.

m) Images recorded on our CCTV systems or taken of you by photo or video with your consent.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not intentionally collect the following Special Categories of Personal Data about you (except where detailed immediately below): details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and information about genetic and biometric data.

We do collect details about your vehicle, health and criminal convictions for the purposes of assessing the risk of providing you with a rental vehicle (and insuring the vehicle and/or your property) in some instances. We may collect health data when discussing any vulnerabilities you may have so that we can assist and support you. We may also collect special category data or criminal offence data when processing your data via our vehiclebased inward-facing dashcams. We do not collect or process personal data of anyone under the age of 18 for the purposes of supplying our products or services.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, webchat, email or otherwise. This includes personal data you provide when you:
• apply for our products;
• create an account on our website;
• request marketing to be sent to you; or
• give us some feedback or submit messages to us.
• Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also collect your data on our CCTV systems if you visit any of our offices. We also deploy AI systems in different parts of the business, and these collect Identity, Contact, Policy and Claims data. For more information on our use of AI systems, see Section 4.
• Technical Data from use of the telematics tracking device (as further described in this notice).
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

1. Insurance Brokers/Financial advisers
2. Card associations
3. Credit reference agencies
4. Insurers
5. Taxi operators
6. Comparison websites
7. Social networks
8. Fraud prevention agencies
9. Payroll service providers
10. Land agents
11. Public information sources such as Companies House
12. Agents working on our behalf
13. Government and law enforcement agencies.
14. 3rd Parties that provide evidence in relation to claims
15. Your employer (Fleet Policies only)
16. The Motor Insurers’ Bureau (MIB) via their MyLicence online service

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter in to or have entered in to with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data however if we do, you have the right to withdraw consent at any time by contacting us, using the email address in section 1 of this notice.

We may also collect your data when our policyholder nominates you to act on their behalf, or where you are identified as a named driver on one of our policies. If you are the Policy Holder, you must have the named driver’s permission to share their data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Please note we reserve the right under legitimate interests to share your data for the purposes of sale, transfer or merging of our group of companies.

Fraud Prevention

Before and during the provision of services or goods to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We process your personal

data on the basis that we need to take steps to prevent fraud and money laundering, and to verify identity, in order to perform our contract with you and to protect our business and comply with laws that apply to us. Such processing is a contractual requirement of the services you have requested. We conduct some of these checks using an AI system, as described in Section 4.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

Telephone Calls

We may record telephone calls for training and monitoring purposes, to comply with regulatory obligations, to demonstrate services levels are being achieved or identify improvements, and to assist with the resolution of enquiries and complaints. Wherever possible, on our main telephone numbers, an automated message will notify you that calls are being recorded however please note it may not always be possible to notify you.

Telematics tracking device

Where you purchase a policy from us that requires you to install a telematics tracking device in your vehicle, we will (at the time of usage) collect information on use of your vehicle and how it is driven, including: the speed of your vehicle, acceleration, braking, cornering, time of usage and mileage.

The above information will be used to build a profile of how, where and when your vehicle is driven. We will use this information to identify extreme driving events which could result in an additional fee being charged to you or, the cancellation of your policy.

We will also monitor the data collected from the telematics tracking device to calculate your total mileage. Where this exceeds the amounts stated on the schedule of your total driving mileage (as set out in your policy), your Insurer reserves the right to cancel your policy.

The GPS location data obtained from the telematics tracking device assists us in assessing the types of roads you use and may also help the police recover your vehicle if it is stolen. We may release your data to the police or to a civil authority where we have a lawful basis for doing so, where we suspect fraud (or attempted fraud) or, if we are required to do so by law.

Your device is installed in your vehicle by you, or by our suppliers, Matrix IQ or Flock. They also maintain the device and monitor it for faults. Data from the tracking device is collected by our suppliers, Matrix IQ or Flock , via a mobile data link.

Matrix IQ and Flock may use certain data collected to improve their product and services. This will be carried out in an aggregated format using anonymisation techniques. It is important that you read their Privacy Notice available on their website to understand how your data will be processed. If you have any questions regarding the data collected by our partner as part of the service they provide to you and us, you can contact them via their website as follows:

Matrix IQ – https://matrixiq.com/privacy-policy/

Flock – https://help.flockcover.com/privacy-policy 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Direct marketing

Where you have contacted us about one or more of our products or services, we, and affiliated companies in our group, may send you further direct marketing communications about similar products and services unless you opt-out as directed in our telephone automated message system. We may contact you by email, text message or by phone based on your marketing preferences. We will ensure that you are given the option to update your marketing preferences when you first contact us and whenever we send marketing communications.

Affiliated companies in our group are Acorn Insurance and Financial Services Limited, , MyPolicy, and Granite Finance Limited.

It is important to note that you have the right to ask us to stop directly marketing to you at any time by contacting our data protection team on [email protected] or by telephone with our customer service department, using 01704 339000 Option 3

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website, products and services. For detailed information on the cookies we use and the purposes for which we use them please see paragraph (b) below.

We may use them for:

1. per-session cookies are used while you are logged on to our website to record temporary data relating to your visit to our website, to manage the delivery of webpages to; you and any registration and ordering processes, and to help us monitor traffic through the Website; and
2. logon and usage cookies store some data between visits to our Website in order to allow you to log on to your account more easily, and using them we are able to personalise your experience and create a database of your previous choices and preferences, and in situations where those choices or preferences need to be collected again, they can be supplied by us automatically, saving you time and effort. For example, after you purchase a product once, if you need to purchase it again your previous selection of options will be retained and can be re-entered more quickly.
3. performance cookies that allow us to understand how visitors use our websites and where appropriate help us to provide marketing communications that we think may be of interest to you (where we have a lawful basis to do so).

If you do not want to use cookies most internet browser programs have extensions that will allow you to block them . Should you do this you will still be able to access most of our website as normal but some processes that depend on cookies may not work properly. We also provide the choice as to which cookies to accept.

Purposes of disclosure and recipients

We do not share personal data with any third parties except as provided below or as required by law:

a. DVLA

We may provide Your driving licence number to the DVLA in order for a search to be carried out to confirm Your licence status, entitlement and relevant restriction information and endorsement/conviction data. Searches may be carried out as part of Our validation enquiries and at any point throughout the duration of Your contract with Us. A search with the DVLA will not show on Your driving licence record. For details relating to information held about You by the DVLA, please visit www.dvla.gov.uk. Undertaking searches using Your driving licence number helps Us check information to prevent fraud and reduce incidences of negligent misrepresentation and non-disclosure.

b. Payment processing

Your personal data may be processed by third parties who provide other processing services to us and we may transfer personal data to third party payment processors in order to process payments for orders (such as credit and debit card processing companies). If we use a third-party order processing service, they will collect and send your data to us securely, which will then be incorporated into our databases.

c. Private hire vehicle licencing authorities

We share Your data to verify the validity of Your and Your vehicle’s taxi licence.

d. Local or District Councils and Law Enforcement

We share Your data to prevent, detect, apprehend, and/or assist in the prosecution of offenders. We provide Your Personal Data for the administration of all charges, fines and court costs including congestion charges, parking, traffic, speeding or other offences, and any civil penalties You may be liable for.

e. Insurers / Brokers

We will share your data with your Insurer.

f. Third parties involved in a claim

We will share Your data with third parties involved in a claim, such as their insurer, solicitor or representative.

g. Third party service providers

In addition to the third parties we have already mentioned in this privacy notice, we may have your personal data processed by other third parties throughout the world who act for or on our behalf; for example, we may use cloud computing or remote database hosting services which may be located anywhere in the world and we may engage contractors anywhere in the world for the purposes of providing support or back-office services to us, including website hosting, order processing, order fulfilment, application and database hosting, data processing services, or that help us market out products and services. These companies will process and hold information about you in order to perform their functions. These companies are not authorised to use the information they process for us for any other purpose than those to which we have notified you under this privacy notice. Please see ‘International Transfers’ in section 6.

h. Group companies

For operational efficiency and to ensure you are provided with the best possible service, certain services and operational activities may be carried out on our behalf by other companies in our Group. We ensure strict measures are in place between the companies in our Group to ensure your personal data is processed in accordance with this privacy notice.

i. Taxi Operators

We may share certain personal data to verify the status/terms of your motor insurance policy (“insurance verification”) with your designated taxi operator. We do this to assist you in verifying your insurance documents, and, to support the operator in ensuring their drivers maintain the required insurance in accordance with regulatory requirements. Your taxi operator will have communicated with you about your participation in such verification service if this arrangement is in place. Your operator will not be authorised to use the information for any other purpose.

j. Legal requirements and Regulators

We may share or transfer your personal data to a government authority where required to comply with a legal requirement, for the administration of justice, or where reasonably required to protect you or your company’s vital interests.

k. Corporate Transfer

We may transfer your personal data to any company that purchases or otherwise acquires our business in the event of a corporate sale, merger, reorganisation, dissolution or similar event.

l. Statistics

We may use your personal data along with other data to provide statistics on an anonymous basis to our contractors, marketing partners (including banks and other institutions who may promote our products to their customers), and other companies and organisations we deal with, for a range of purposes, including assessing and reporting on the overall performance of our products and website, assessing and reporting on overall Page | 13 product take-up and usage, assessment and reporting on malware and unsafe websites and associated threats and risks in general or for any group of customers

m. Identity Checks

We carry out identity checks when you apply for our PCO Rent to Buy scheme. We use a third-party supplier to carry out the checks.

n. Social Media Companies

We also use various social media channels to allow you to share claims information, provide support and answers for you and/or as part of our marketing activities. Whilst we never add anyone’s personal data to any social media channel, we do use their audience and category advertising features.They act as joint (cookies) or separate controllers (if you contact us via the social media channel) with us, as they determine how your data is managed after you engage with us.

WhatsApp privacy notice (Meta)

Facebook privacy notice (Meta)

Instagram privacy notice (Meta)

X  privacy notice

Youtube (Google)

LinkedIn

o. General Suppliers

We have partners providing risk management, validation and telematics services, and we share your data with them in order to provide you with services or a quote.

We also offer optional add-ons for your vehicle rental and we share your data in order for them to be able to provide these services. These suppliers act as data controllers for your data, which means they determine the means and purpose for processing your data.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International Transfers

Where we transfer personal data outside the UK or European Economic Area (EEA), we will work with our service providers and partners to ensure appropriate safeguards are in place to protect your personal data and your privacy rights, meeting the standards required to Page | 14 make such a transfer lawful.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we are required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for the term of their policy and for a period of seven years after they cease being customers.

In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Customer means any person (including individuals, firms and companies and other organisations) who is a customer of Acorn Insurance, including persons who browse, register on or otherwise use our website, or who purchase our products.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.