Small Accident Repair Technology Limited (hereafter referred to as “SMART” in this privacy notice) are committed to protecting and respecting your privacy. On this page we describe how we may make use of any personal data that you may supply to us as a policy holder, when you visit this website and/or the Smart Insurance mobile application (the “SMART App”). Please read the following to carefully understand our views and practices regarding your personal data and how we will treat it.
Additional privacy information in relation to your use of the SMART App can be found later in this policy.
This privacy notice aims to give you information on how your personal data is collected and processed in connection with your SMART insurance policy, as well as how your personal data is collected and processed through this website.
Red Sands Insurance Company (Europe) Limited and Aioi Nissay Dowa Insurance Company of Europe Limited are the joint controllers and jointly responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details (including registration and address details) can be found within your policy wording.
Small Accident Repair Technology Limited (referred to as “SMART” in this privacy notice) have been appointed to act on our behalf in respect of all matters relating to the protection of your personal data and to oversee questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact SMART using the details set out below.
b) Contact details for SMART
The Data Privacy Manager
SMART Insurance Services
Unit 14, Rawdon Business Park
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
c) Informing us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 as set out below:
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. 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 collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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 insurance 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.
How is your personal data collected?
Your personal data is collected by the motor vehicle dealer from whom you purchased your insurance policy and is passed to SMART (either directly or sometimes by a third-party system used by the motor vehicle dealer). SMART collect the data on our behalf and pass it to us. In addition, you may contact SMART directly to update your details from time to time – SMART will pass on any such updates to us.
We may collect and process the following data about you:
(a) Information you provide to us
You may give us information about you by filling in forms on this site or by corresponding with us, by phone, e-mail or otherwise. This includes information you provide when you make any request using this site (e.g. to be kept informed of SMART offers) or when you report a problem with our site.
The information you give us may include;
Depending on your use of our site we may collect some or all of the following personal data:
(b) Information we collect about you
This website uses server logs which record your interactions with this website in terms of the webpages you visit by reference to your computer’s internet protocol address at the time. We may use the data generated by these logs to analyse site usage and to investigate any site performance issues.
We do not use such data to identify individual internet users unless we believe they may be involved in unlawful, malicious or offensive conduct.
(c) Information we receive from other sources
We work closely with certain third parties, including business partners, sub-contractors in technical services, analytics providers and search information providers and may receive information about you from them.
Links to third party websites
We only use the personal data that you supply to us for the following purposes:
(a) to fulfil a request you make of us through this website, e.g. to make a claim or to provide you with information requested about our products and services.
(b)to contact you with information about our products and services if you wish for us to do so. You may opt how you wish to receive such information or not to receive it all;
(c) As part of the recruitment process, when applicable;
(d) to contact you if we experience problems in fulfilling one of your requests in a timely manner;
(e) where collected with your permission as part of a survey for survey purposes connected with that survey;
(f) for marketing research, data analysis and troubleshooting. Where we are using any data for analytics, we will only use that data to observe trends and it will not be used in a way that could identify any particular individual;
(g) to repair and improve this site or ensure that the content on our site is presented in the most effective manner;
(h) as part of our efforts to keep this site safe and secure;
(i) to detect or prevent unlawful, malicious or offensive activity; or
(j) to comply with an order of a Court of Law of competent jurisdiction.
When you make request of us, you can select whether you wish to be kept informed of our products and services. If you say no then we will remove or suppress your personal data from our databases once we have fulfilled your request. If you opt to receive information using a certain method of communication only (e.g. by text or email only) then we will remove or suppress any data that relates to any other form of communication.
The legal bases on which we will rely for our processing are that the activities are either necessary to perform our insurance contract with you, necessary for our legitimate interests or are necessary to comply with a legal obligation.
In this privacy notice, “legitimate interest” means our interest in conducting and managing our business to enable us to give you the best service/product. 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).
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 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.
We may share your personal information with certain affiliate organisations to allow them to fulfil specific requests made by you, and other companies in our group. Your personal data will never be sold or provided to any individual or organisation outside of our group, its agents or affiliated companies. We will not use your personal data for any purpose that we have not previously disclosed to you.
(a) Use of data processors
We may use agencies to fulfil your requests, to track activity on our website and perform data analytics or site optimisation. All agents that we use are required to keep your personal data secure and to process (i.e. to store, handle and, if needs be, erase) it in accordance with our instructions. Your personal data will not be used for any purpose that you have not previously consented to.
(b) Sharing of data
We may have to share your personal data with the parties set out below for the purposes set out above:
In addition, your personal data will be hosted, shared and monitored using third-party infrastructure providers, data sites or systems, and external IT contractors and suppliers may have access to your personal data in the process of providing services to us.
We may also share data with third parties to detect and avoid fraud or other criminal activity.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The transmission of information via the internet can never be guaranteed to be completely secure. While we will do our best to protect your personal data, we cannot absolutely guarantee the security of any data transmitted to our site. Any transmission of data is made at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
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 have to keep basic information about our policyholders for 7 years after their policies expire.
In some circumstances you can ask us to delete your data: see below for further information.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below.
If you wish to exercise any of the rights set out below, please contact us via SMART using the contact details at the start of this privacy notice. We may not have to comply with your request but we would explain why if we believe we are entitled to refuse.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have concerns about the way we handle your data please do not hesitate to contact us using the details provided at the end of this privacy notice. If we are unable to help, you also have the right to lodge a complaint with the Information Commissioner’s Office.
All data subject access requests made under the Act should be sent to:
The Data Privacy Manager
Smart Insurance Services
Unit 14, Rawdon Business Park,
Marquis Drive, Moira,
Derbyshire, DE12 6EJ
By downloading or streaming a copy of the SMART App onto your mobile telephone or handheld device (“Device”) you are accepting and consenting to the practices set out in this policy. Where any of the services accessible through the SMART App (“Services”) are available on this website, the privacy terms applicable to this website shall apply equally to the SMART App. In addition we may collect and process the following information:
(a) Information you provide to us:
This is information you give us about you by filling in forms on the SMART App, or by corresponding with us (for example, by e-mail or contact form). It includes information you provide when you register to use the SMART App, download or register the SMART App, make a claim, enter a promotion or survey, and when you report a problem with the SMART App or our Services. If you contact us, We will keep a record of that correspondence. The information you give us may include your name, address, vehicle details, e-mail address and phone number, the Device’s phone number, and other registration information.
(b) Information we collect about you and your Device:
Each time you use the SMART App we will automatically collect technical information, including the type of mobile device you use, a unique device identifier, mobile network information, and your mobile operating system. We also use mobile connection technology to determine your current location. This information is captured via Google Analytics and anonymised, so that we are not able to identify you personally.
The Data Privacy Manager
Smart Insurance Services
Unit 14, Rawdon Business Park,
Marquis Drive, Moira,
Derbyshire, DE12 6EJ