In this privacy policy when we say ‘Dayinsure’, ‘we’, ‘us’ or ‘our’, we mean Dayinsure.com Limited, an insurance intermediary providing short term and learner car insurance. We are a subsidiary of Ormiston Holdco Ltd and part of the Abacai Group (“The Group”). You can click here more information on The Group.

The security and privacy of your personal information is very important to us and we want to assure you that it will be properly managed and protected whilst in our hands. This Privacy Policy explains how, why and when we use your personal information.

We are a controller of your data. This means we determine the purpose for which we use your personal information and the way in which it is used. We have partnerships with a number of insurers and other introducers.

When you take out an insurance policy then a third party insurer or ‘underwriter’ will also be a controller of your data.

Where a third party is a controller of your data we strongly recommend you review their privacy policy so you can understand how they will collect, store, use and share your information.

We have appointed a Data Protection Officer who is responsible for the way we handle personal data. If you wish to know more or get in touch, you can do so by using the details in the “How to contact us about your requests or concerns” section below.

In order to provide you with our services, we collect, process and hold only the personal data we need.

What information we collect about you will vary depending on the service involved and your personal circumstances, but includes:

• basic personal information including name, address, contact details and date of birth
• information about your work or profession
• your nationality
• details of the products held with us and how you use them
• financial information such as credit/debit card details and details of payments you have made to us
• information on claims you have made
• personal information gathered when you’ve applied for a product, including where an application was declined
• information about how you interact with us, our website and our services (e.g. Dayinsure Mobile apps)
• medical, criminal offence or other such sensitive information*
• accessibility details if we need to make reasonable adjustments to help
• government identifiers such as driving licence number, passport numbers
• machine identifiers including your IP address
• information about others in relation to registered car ownership
• information on the vehicle you are seeking to insure, some of which will be collected from external databases.

*This could include highly sensitive information also known as “Special Category” personal data or criminal offence information. We always minimise the use of such data and will only use your more sensitive types of data when absolutely necessary.

Our website may include links to and from the websites of our partner networks, advertisers, and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for them. You should check how an organisation processes data before you submit any personal data to their websites.

We collect information about:

• previous, current and prospective customers/policyholders
• previous, current and prospective parties covered under an insurance policy we arrange
• persons authorised to speak to us on behalf of a customer or policyholder
• users of our websites.

If you provide personal information to us about other individuals you should:

• make sure you only share an individual’s personal information with us if you have their permission to do so
• share this Privacy Policy with all individuals whose information is provided to us.

We may obtain personal information in a number of different ways:

• from you or someone connected to you*
• companies and organisations that introduce you to us
• comparison websites
• from third party databases used by the insurance industry (e.g. DVLA, Motor Insurers Bureau, Claims Underwriting Exchange)
• credit reference agencies
• government bodies and agencies
• law enforcement agencies
• fraud prevention agencies
• insurers and insurance underwriters (claims information)
• the Electoral Roll and other sources of publicly available information**
• our service providers
• market research providers
• organisations providing data services to support us in managing our relationship with you and operating our business
• from other companies within the Abacai Group
• social media (if you have made information publicly available).

*if someone acting on your behalf provides us with information, we’ll always record what’s been provided and who gave it to us.

**Our product and application contains public sector information licensed under the Open Government Licence v3.0. For further information in relation to the full terms of Open Government Licence please refer to URL: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/

We collect and use your information so we can arrange and administer your general insurance products and to operate our business. We only collect personal information which is necessary and will only use that information when it is appropriate to do so.

UK data protection law requires that we have a reason to process your personal information. The most likely reasons we will collect and use personal information are:

Providing services which relate to a quote and/or insurance policy as part of a contractual relationship, including:

• Applying for and arranging insurance
• Referring to relevant databases to verify information provided
• Evaluating your application and ability to pay for your policy by instalments. This may involve sharing your personal information with credit reference agencies. (See our section “our use of credit reference agencies” for more detail)
• Ongoing management of your policy including amendment, claims, complaints and notifying you of changes to your policy.
• Providing you with the services we have committed to in your policy documents and allow you to participate in interactive features of our services / websites. This may include the transfer of your information to third parties where this is necessary for the provision of a service or product feature.

When we assess an application we use computer systems to make what are known as “automated decisions”. More information on this can be found below in the section “When do we use your personal information to make automated decisions about you?” Use of your personal information is a necessary part of assessing your application, providing you with a quote and offering you insurance. Without this information we will be unable to provide you with cover.

Where our business interests mean it is reasonable and justifiable for us to do so (known as a legitimate interest), including:

• Collecting information about you from databases as described in this notice and verifying information you provide against those databases
• Strictly necessary website cookies such as those which allow the navigation and use of essential website features, or for website maintenance and improvement. More information can be found in our Cookie Policy.
• Providing you with a quote
• Sharing information with other firms, industry and public bodies necessary to the conduct of our business
• Recovering payments due to us
• Data analysis to support, review and improve our products and services
• For development of our business operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes
• Audit and quality control to improve our customer service and training and to run our business well, this includes call recording or monitoring and may include the use of voice analytics.

Where we have your permission to do so:

• To provide you with information about products or services we feel may interest you (see our section on Marketing for more information)
• Where personal information is supplied by an individual who holds no contractual relationship with us but gives us permission to collect, store and use their personal data (e.g. a parent or guardian of a learner driver)
• The collection, storage and / or use of children’s personal information where this is necessary for the usage being undertaken (e.g. learner drivers under the age of 18)
• Where you have given your consent for the use of certain types of optional website cookies, such as those which personalise your repeat visits to our websites or allow third parties to conduct web analytics. More information can be found in our Cookie Policy.

Where there is a legal requirement to share personal information:

• To assist with the prevention, detection or investigation of criminal offences (e.g. fraud, money laundering or organised crime), this includes the sharing of information in line with a legitimate request from a UK law enforcement agency.

Our approach to using particularly sensitive types of personal information such as criminal offence and special category information):

• When we collect, store and use certain types of sensitive information such as special category (e.g. health or medical records) or criminal offence data, data protection law includes additional safeguards
• When we use personal information that relates to a criminal offence we will usually do so for an insurance purpose
• Similarly if we do have cause to use your special category information, we will normally do so with an additional justification. This will usually be when the processing is necessary for the establishment, exercise or defence of legal claims or when there is a substantial public interest in processing it for insurance purposes (i.e. the processing is a requirement which contributes to the wider public benefit which results from the UK insurance industry).

We will always minimise the use of this type of information.

We take the privacy and security of personal data very seriously. We will only ever share your personal data in a manner consistent with UK data protection law. To give you peace of mind Dayinsure will never sell your data.

As part of operating our business we may share your personal data with the following:

• Other brands or companies within the Abacai Group of companies (see About Us section for more information)
• Other insurers, partners, agents or carefully selected third parties – This is usually when we use a third party to fulfil a service to you on our behalf (e.g. breakdown cover) or when a third party is providing us with a service (e.g. professional advisers such as legal firms)
• Third parties that we use to help us identify and maintain accurate information, detect financial crime, detect fraud, update on UK sanctions, or provide assistance with investigation in cases of suspected fraud
• Companies we partner with to provide you with insurance (e.g. introducers, insurance underwriters). You will be notified of who your insurer is both when you take out a policy and in your policy documents. We strongly recommend you also review the privacy policy of your underwriter so you understand how they will collect, store and use your information
• We share information with credit reference agencies to assess your credit history. You can find more information on this in our use of credit reference agencies section
• Statutory, regulatory, supervisory or otherwise authorised public bodies to provide necessary information (examples include the Financial Conduct Authority and the Information Commissioner’s Office)
• Organisations where we have a duty to disclose your personal information under applicable law (e.g. a UK police force or court)
• Insurance industry bodies such as the Motor Insurers’ Bureau (MIB) and the Association of British Insurers (ABI)
• Third parties with whom you have given us permission to share your information and it is reasonable for us to believe they are acting on your behalf or when you have agreed to benefit from an offer of service fulfilled by them (e.g. promotions associated with a purchase)
• We may pass information to third parties for the fulfilment of marketing communications. This will only be completed where we have appropriate permission to do so. More information on this is available in our section on Marketing
• Another company, where part or all of our business is being sold to them. To ensure cover continues uninterrupted and, as part of any potential sale, we may share personal information with the purchasing party. Any prospective purchaser would be under a strict duty of confidentiality which covers all personal information that is shared with them.
• Transfer of your information following sale of your policy to another insurer. If this happens we would specifically notify you of this and you will be able to exercise your right to object (see the your information rights section for more detail on this right)
• Piloting improved systems and services. This may be facilitated wholly or in part by third parties.

UK data law includes standards of data protection designed to keep your personal information safe.

We always seek to keep your personal information within the UK. If we do need to transfer, store or use personal information we hold outside of the UK, we will either confirm that the location your information is being processed is one the UK Government has determined equates to the UK’s own standards (known as “adequacy”), or we will put in place additional protections to make sure it remains suitably secure and compliant with UK law. This means your information should keep a similar level of protection at all times.

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside of the UK.

We only keep your personal information for as long as is necessary, as set out in this Privacy Policy and in order to meet our legal, regulatory and contractual obligations.

We have in place a Data Retention Policy which governs how long different types of personal information should be retained by us. The policy is reviewed on a regular basis to ensure that it follows current legal and regulatory requirements.

It is important that you are aware that retention periods vary depending upon the circumstances of an individual matter, but in general our retention periods for customer facing documentation can be set out as follows:

We may, along with our trusted partners (Aviva and companies within the Abacai Group), provide you with marketing offers on products and services. When we do, we will always give you the opportunity to ‘opt out’ of direct marketing when you request an online quote, purchase a product online or receive any email, text or other direct marketing communication.

In addition, you can always request we stop contacting you about products and services directly. You can do this either by getting in touch through the channels identified in your product documentation, or by using by using the contact details provided in the “How to contact us about your requests or concerns” section of this privacy policy.

Although requesting this will mean we stop all communications promoting products or services, we will of course continue to send you service related communications where necessary.

We use computers to make automated decisions about you. This means our systems use automatic processes rather than being made by our employees. This is known as ‘automated decision-making’.

When we assess your insurance application we will use an automated decision to apply our pricing and business acceptance rules. This decision will determine both whether we can provide a quotation and, if so, at what price. The information you provide to us about yourself and about other relevant individuals will be used to make this decision.

As part of our assessment we will use information sourced from third party companies such as credit reference agencies. This assessment will involve driving licence checks and the review of relevant information including verification of residence at the address provided, historic payment behaviour on financial products, prior insolvency and any relevant past county court judgements. For more information please see the section in this notice on Our Use of Credit Reference Agencies.

You have a right to not be subjected to automated decision-making without human intervention, however you should be aware that some of the automated decisions we make are a necessity of providing you with an insurance quotation and objecting to their use may result in us being unable to offer you a policy. For more information on your right to human intervention please see our section on Your Information Rights.

To assess applications and amendments we undertake checks with credit reference agencies. The personal information you have provided to us will be shared with them so that they can provide us with information about you relevant to your application. This is what is commonly referred to as a “credit check”.

Dayinsure only performs a soft credit search, which may be recorded on your personal credit report so that there is a transparent record of which companies have been viewing your credit history. This type of search will not affect your ability to apply for credit. You can get a copy of your credit report at any time from a credit referencing company. Please note: Not every soft credit search will result in a visible ‘footprint’ being left on your report.

For further information about the ways credit reference agencies use and share personal information go to https://www.experian.co.uk/legal/crain/

You have a number of rights when it comes to your personal information. We want to make it as easy as possible for you to understand what these rights are:

*Whether or not we meet a rights request depends on us balancing your request against other factors such as legal and regulatory requirements, the purpose of a contract between us and you or if there is a compelling legitimate ground not to. However if we are not going to meet your request in part or in full we will always advise you of our decision to not do so.

If you wish to make a data rights request please email support@dayinsure.com, we will acknowledge your request and prepare a response within one month.

More information on the ICO’s approach to complaints can be found at www.ico.org.uk/concerns. Making a complaint will not affect the other legal rights or remedies that you have.

If you wish to exercise an information right or have a complaint about how we gather, keep or use your information, you can get in touch with us:

By post: Dayinsure.com Ltd, Mara House, Nantwich Road, Tarporley CW6 9UY

ICO registered Data Protection Officer: Alexander Peters

Email: support@dayinsure.com

Tel: 0333 005 0944*

*Important information: For our joint protection, telephone calls may be recorded and/or monitored and will be saved for a minimum of five years. Calls to 0800 numbers from UK landlines and mobiles are free. The cost of calls to 03 prefixed numbers are charged at national call rates (charges may vary dependent on your network provider) and are usually included in inclusive minute plans from landlines and mobiles.

We may amend this Privacy Policy from time to time to reflect important changes which affect how we collect, keep or use personal information. Updates will usually be in response to changes in the way data protection law is written or applied.

You should check our website periodically to view the most up-to-date Privacy Policy.

This Privacy Policy was last updated on: 25/10/2022

Version: 3.5