Unless stated otherwise, in this policy "Endsleigh Loop", "we" and "us" mean Endsleigh Insurance Services Limited (Company 856706), trading as ‘Endsleigh Loop’, registered in England at Shurdington Road, Cheltenham Spa, Gloucestershire GL51 4UE.
Endsleigh Insurance Services Limited, trading as Endsleigh Loop, is a data controller of your personal information. Endsleigh Insurance Services Limited is owned by Endsleigh Limited, which is a member of the A-Plan group of companies.
Your insurer’s privacy notice
For full details of your insurer’s privacy notice, please contact them directly (their details will be shown on your policy schedule).
Your finance provider’s privacy notice
For full details of Premium Credit Limited’s privacy notice, please contact them directly. Further information can be found on their website https://www.premiumcredit.com/
Information we collect to give you a quote
We collect and process personal information that you provide via our website, via price comparison websites or when you contact us, including some information we collect automatically. We also collect information about you from other sources, including information you have voluntarily made public.
Information you give to us
We collect and process personal information that you give us when requesting a quotation, when you buy from us, when you advise us of a change or when making a claim.
The personal information we collect includes:
- your personal details e.g. your name, date of birth, occupation, email and telephone numbers
- Vehicle details, named drivers, your occupation, driving licence details, any criminal offences and the claims history of all drivers
- your insurance claims and credit history
- bank account or credit/debit card details and payment preferences
- higher education details e.g. student or graduate status, course and place of study
- membership of professional associations we have a relationship with
- sensitive personal information such as criminal convictions, health, union membership and time resident in the UK
- online account details e.g. username, password, IP address and usage history
- All the above information about any other named drivers to be insured under the policy
This information is necessary for us to be able to provide you with a quotation and/or policy.
Other sources of information
We also use a number of different sources to collect this information from, including:
- Publicly available sources of information, such as social media and networking
- Third parties’ databases that are available to the insurance industry, as well as where you have given your permission to share information with third parties like us
- Price comparison websites, if you have used them to obtain an insurance quotation.
The assessment of your insurance application may involve an automated decision to determine whether we are able to provide you with a quotation and/or the price. If you object to this being done, then we will not be able to provide you with insurance.
Credit checks for insurance quotations
When you ask us for an insurance quotation, we will ask a credit reference agency to provide your credit score, which you too can obtain from any credit reference agency. The information we receive as a result is based on public data including the edited electoral roll, county court judgements, Scottish decrees and bankruptcy registers. This quotation search is recorded by the credit reference agency but does not affect your credit score. You can find out further information about how the Credit Agencies collect and use personal data at https://www.transunion.co.uk/crain.
When you ask us for an insurance quotation we will carry out anti-fraud checks to validate your application. We will search third party fraud prevention and detection databases, and if we suspect fraud, Endsleigh or insurers can decline to offer you insurance.
If you proceed to buy an insurance policy from Endsleigh, please be aware that these searches are conducted again when your policy is due for renewal. If you choose to pay by monthly Direct Debit, your details will be sent to a premium finance provider, or your insurer as appropriate, who will assess your application and may carry out additional credit and anti-fraud checks which could affect your credit score.
Higher education and professional association checks
Endsleigh maintains relationships with education related organisations and institutions, unions, professional bodies, charities and other employers. Endsleigh uses the personal information you provide, together with data from these organisations to refine the insurance quotes we provide.
Sensitive personal information
Data protection legislation permits us to collect and use sensitive personal information (e.g. criminal convictions, health records, union membership and the time you’ve been resident in the UK) without requiring your consent.
How we use your information
We use your personal information and/or special categories of personal information not only to provide you with this insurance policy, but to better understand and predict your needs and preferences, so that we can continue to improve our products and services to give you insurance that is right for you.
How we use your personal information
Endsleigh Loop, Ingenie Limited and our selected third parties collect and use your information to meet our legal obligations, and for these legitimate business purposes:
- Quote for, provide or administer insurance or related products and services.
- Assessing your insurance application and arranging your insurance policy, including checking databases showing no claims discount entitlement and driving licence records
- Managing your insurance policy, including claims handling and issuing policy documents to you
- Process payments or refunds or arrange premium finance loans
- Record or process insurance claims
- Communicate with you about products you own or services you use
- Detect or prevent fraud and other crimes
- Verify your identity when you contact us or use our services
- Verify your higher education or professional associations (personal insurance only)
- Ask for your views on our services
- Analyse, develop and improve products and services we offer
- Operate and secure our systems, offices and facilities
- Maintain our accounts and records
- Investigate and resolve complaints and respond to enquiries
- Trace debtors or beneficiaries and recover debt
We keep the amount of information collected and the extent of any processing to the minimum to meet these legitimate business purposes.
Dealing with others acting on your behalf
We normally need your consent before we permit other people you trust to act on your behalf. Therefore, we will deal with individuals you nominate, including third parties we reasonably believe to be acting on your behalf providing they are able to answer our security questions. For your protection, we will need to speak to you, your legal representative or someone with power of attorney should you wish to change your address or level of cover or cancel the policy.
Endsleigh Loop partner with Ingenie Limited to provide services related to your insurance policy. Ingenie Limited also use third party companies to help them do this, for example supplying the telematics device and related IT systems.
The telematics data
The telematics data collected by Endsleigh Loop and Ingenie Limited includes information on a range of your driving characteristics including:
- Speed throughout your journeys
- Braking frequency and force
- Cornering and sudden manoeuvres/movements
- Miles travelled
- The types of routes you take (e.g. A-roads, motorways, country lanes)
- Times and dates of travel
- The car’s GPS location
Your Endsleigh Loop device will begin to collect your telematics data:
- following installation; or,
- with immediate effect, if the car already has a telematics device installed and we have been able to reactivate it.
Please note that if you allow other drivers to use the car during the period of insurance, we will continue to collect telematics data from the device.
If the policy is cancelled, or lapses, we will cease collecting your telematics data within 7 days of cancellation, or as soon as possible thereafter, meaning the Endsleigh Loop device will not transmit any further telematics data to Endsleigh Loop or Ingenie Limited.
Any telematics data collected remains the property of Endsleigh Loop.
How Endsleigh Loop uses the telematics data it collects
In brief, Endsleigh Loop takes your telematics data and uses intelligent software and algorithms to assess your driving behaviour. This behaviour is then given a score, which is regularly updated as the driving characteristics identified by the Endsleigh Loop box change over time.
For example, if you consistently exceed the speed limit or take corners too sharply for the kind of car you drive, the analytics algorithms will detect this and your score may be lower as a result. If you then begin to reduce your speed and drive more carefully, your score is likely to increase over time.
Other uses of your data include:
- making your score available for you to access from Endsleigh Loop via your feedback account;
- issuing messages relating to your driving behaviour, such as red messages and black messages;
- creating detailed assessments of your driving behaviour or specific information relating to the car at or around a particular event e.g. if an accident involving the car occurs, we will request a breakdown of the exact telematics data recorded immediately prior to and following impact.
- To provide and administer a rewards scheme
All the personal data and telematics data that Endsleigh Loop passes to your insurer is held by the insurer in accordance with the insurer’s Data Protection Notice, which is detailed in your insurance contract.
Endsleigh Loop, Ingenie Limited, or a third party acting on their behalf may need to pass some or all of your personal data and/or telematics data to selected third parties. If this is necessary, the transferred data will be held securely in accordance with data protection law. Endsleigh Loop, or any company acting on their behalf, will not typically disclose specific telematics data e.g. a report on where you have driven over the course of a given period, though Endsleigh Loop may disclose detailed usage data in the event of a claim.
Third parties include:
- Your insurer: to provide and manage your insurance and other similar activities
- a different insurer from time to time: to provide you with a quote, or additional insurance policy e.g. after-the event insurance cover for accidents, where you have requested this cover and your primary insurer is either unable or unwilling to provide it
- relevant authorities such as the Motor Insurers’ Bureau, or any disclosure which is required by a court order
Endsleigh Loop will own and retain all intellectual property rights in all data uploaded to or held in the portals.
Recording and monitoring communications
We routinely record and monitor calls, emails and other communications to improve our service and for security and regulatory purposes.
Cookies, web tracking and similar technologies
When you use our website Endsleigh Insurance Services Limited automatically collects information such as your IP address (the unique address identifying your device from all the others on the internet), what type of device you are using (e.g. a tablet, phone or PC) and cookies from your device.
Our website contains web technologies that collect information from your movements around our website and the data you enter. Endsleigh uses this information to improve the design of our website, for profiling and for decision-making, but not for marketing or sharing with third parties for marketing.
Cookies are used to compile anonymous website usage statistics, for fraud prevention and to measure the effectiveness of our online advertising campaigns.
Keeping you informed/Marketing
If you have given your consent, Endsleigh Loop may use your contact details, to contact you by email, text, phone or post about products, discounts, rewards or competitions we think will interest you from Endsleigh Insurance Services, or another company within the A Plan Group
Please note: We do not share your information for marketing purposes with anyone outside of the Endsleigh group of companies.
If you change your mind at any time and wish to withdraw your consent to this contact, you can either click the unsubscribe link in our emails or contact us.
Fraudulent claim detection and prevention
Insurers pass information to the Claims and Underwriting Exchange Register, run by Motor Insurers' Bureau (MIB) and the Motor Insurance Anti-Fraud and Theft Register, run by the Association of British Insurers (ABI). The aim is to help us check information provided and also to prevent fraudulent claims. When we deal with your request for insurance, we may search these registers.
Under the conditions of your insurance policy, you must tell us about any incident (such as an accident or theft) which may or may not give rise to a claim. When you tell us about an incident, we will pass information relating to it to the registers.
In order to prevent and detect fraud, we may at any time:
- Share information about you with other organisations including the police
- Conduct searches about you using publicly available databases
- Undertake credit searches
- Check and/or share your details with fraud prevention and detection agencies.
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.
Endsleigh and the insurer or other organisations may 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 and tracing beneficiaries
- Checking details on proposal and claims for all types of insurance
- Checking details of job applicants and employees
The information recorded by fraud prevention agencies may be stored in other countries and used by the Insurer and other organisations from these countries.
Please contact us by email to email@example.com if you want to receive details of the relevant fraud prevention agencies.
Motor Insurance Database
Information relating to your motor insurance policy will be added to the Motor Insurance Database (MID) managed by the Motor Insurer’s Bureau (MIB). MID and the data stored on it may be used by certain statutory 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:
A) Electronic licensing
B) Continuous insurance enforcement
C) Law enforcement (prevention, detection, apprehension and or prosecution of offenders)
D) 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, 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. You can find out more about this from your insurer, or at www.mib.org.uk.
Who we share your information with
- We may share your personal information with a number of different organisations, such as: other companies in the Endsleigh group of companies, or companies affiliated to us
- associated companies including insurance companies, premium finance providers and our other suppliers and service providers (for the purpose of the service they provide to us)
- introducers (including price comparison websites) and professional advisers
- your bank or credit card issuer (payment and refund information only)
- credit reference agencies and fraud detection and prevention companies
- government, regulatory and legal bodies including the Financial Ombudsman Service
- investigators, legal representatives, law enforcement agencies and prosecuting authorities including courts and tribunals
- people who you have told us can contact us on your behalf (once we have verified their identity)
Use and storage of your information overseas
We transfer your data outside of the UK. We have safeguards in place including standard contractual clauses which have been adopted or approved by the EU or other solutions that meet the requirements of European data protection laws to ensure that your personal data are protected to the extent you would expect, were they to remain in the UK. A copy of these safeguards is available from our data protection officer.
We and our service providers may use cloud based computer systems (i.e. a network of remote servers hosted on the internet which process and store information) to which foreign law enforcement agencies may have the power to access. However, we and the service providers that we use will not transfer your information outside the EEA unless it is to a country which is considered to have sound data protection laws, or we have taken all reasonable steps to ensure the firm has suitable standards in place to protect your information.
Keeping your information
We keep your information only for as long as is necessary to:
- Provide our services to you, and
- Meet the purposes for which it was collected, and
- To comply with our legal and regulatory obligations as set out by HMRC, the Financial Conduct Authority and others.
Your data protection rights
You have a number of rights in relation to the information that we hold about you, including:
- Asking for access to, and a copy of your personal information
- Asking us to correct, delete or restrict your personal information
- Objecting to the use of your personal information
- Have personal data about you erased when we no longer need it for the purposes for which it is held, or when we are required to do so by law
- Ask us to restrict the use of your data, if you require it for the establishment, exercise or defence of legal claims
- Object to its use for marketing to you
- Object at any time, to our processing of data about you, although we have a reasonable right to process such data for our legitimate business purposes or in the public interest
- Obtain and reuse your personal data for your own purposes across different providers
- Withdrawing the permission that you previously provided for us to use your personal information, unless laws or regulations permit us to continue such processing.
If you have any concerns regarding our processing of your personal information or your data protection rights, please contact us. If you have raised a concern with us and it has not been resolved to your satisfaction, you have the right to report your concern to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. The Information Commissioner’s Office cannot award compensation. For more information, please see www.ico.org.uk or call the ICO on 0303 123 1113.
Automated decisions and your customer profile
We keep your customer profile that includes information about you that you did not give to us yourself. Where necessary for our contract with you, or where we have authorisation in law or your agreement, we will use your personal information, including your customer profile, to make automated decisions for the purposes of
i) providing quotations for insurance and similar financial products
ii) detecting or preventing fraud or other crimes;
iii) processing claims; or
If you object to this being done, then we will not be able to provide you with insurance. You may, under certain circumstances, have the right not to be subjected to such automated decisions where they have a legal or similarly significant effect on you.
Endsleigh Loop Portal guidelines
Endsleigh Loop will use its reasonable endeavours to provide you with access to the portals 24 hours a day, 7 days a week. However, Endsleigh Loop cannot guarantee that your access will be uninterrupted or error-free. Endsleigh Loop may also need to disable access to the portals for short periods of time in order to carry out planned maintenance on them.
If you are unable to access your account, your telematics data will still be recorded and uploaded when the driving feedback account becomes available again.
When accessing any of the portals, you must:
- keep your password secure, and not share it with anyone who does not have the right to access the portals;
- not store or publish any content on any of the portals that is defamatory, discriminatory or offensive;
- not attempt to de-compile, reverse compile, disassemble, reverse engineer or otherwise reduce to human-perceivable form, all or any part of any portal or the software which underpins it;
- not sell, rent, lease, or use the portals in any other way connected with the provision of services to others; and
- promptly notify Endsleigh Loop if your account or password for any of the portals is compromised.
All the personal data and telematics data that Endsleigh Loop passes to your insurer is held by the insurer in accordance with the insurer’s Data Protection Notice, which is detailed in your insurance contract.
To exercise your data protection rights or to find out more about how we use your information please contact us:
By email to: firstname.lastname@example.org
or in writing to:
Data Protection Officer Endsleigh Insurance Services Limited Shurdington Road Cheltenham GL51 4UE
Requests must be made by the data subject (the person the data relates to), or by someone who we have previously agreed may act on their behalf. We have the right to refuse requests which are excessive, unfounded or repetitive, or where we are unable to verify your identity. We may also ask you to provide additional information or documentation if we are unable to verify your identity.
When making a request, please include
i) your full name and date of birth as they appear on your insurance documents and
ii) any relevant dates, times and reference numbers, particularly policy, quote or claim numbers.