How to contact us
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller, we use (or process) the personal data we hold about you in accordance with this privacy notice.
Data Controller: Compliance Director, Action 365 Limited Trading As Freedom Connect, BizSpace, Cheadle Place, Stockport Rd, Cheadle SK8 2JX
Contact for queries: Compliance Team via email on compliance@action365.co.uky
Your information
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
What type of personal information do we need?
We may need personal details which will include contact details, dates of birth, vehicle data.
We need personal details relating to time, location and driving, including; time, latitude, longitude, speed, duration, distance and acceleration. We will collect event data such as accident detection, unit tampering or activation and deactivation events.
From the Freedom To Drive Smartphone App, which is required for telematics policies we may collect technical data and related information, including but not limited to technical information about your smartphone device, system and application software, and peripherals. In addition, where your policy requires a Bluetooth telematics device, we’ll require access to your Bluetooth status and background location services as defined by the respective Apple, Google and Huawei App stores.
We will only collect what is necessary and will only keep it for as long as we are required to do in line with our data retention policy.
What other types of information do we need?
We also collect information from publicly available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us. We will only collect what is necessary and protect it with appropriate security measures.
How will we use the information you give us?
We will use your information to arrange the installation of your device, administer your telematics driving data and device, for fraud prevention and detection, to undertake market research, product development, for statistical analysis for behavioural analysis and to develop and improve the services which we offer, assist you in the case of an accident or for telematics research and analysis.
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
Purposes for which we process your personal data
The basis on which we can do this (this is what the law allows)
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
- The insurers, intermediaries and third-party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
- Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
- Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
- Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third-party organisation in the interest of preventing and detecting crime
- Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
- Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
How do we obtain your information?
We may gather it from information you provide, by telephone, online, by email, the telematics unit in your car, from the Freedom To Drive Smartphone App, or from surveys or feedback you provide.
We may receive it from Insurers, other insurance brokers, DVLA, industry wide databases, external third-party suppliers working on our behalf, finance providers, price comparison sites and firms handling claims.
What are my legal rights?
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information. If this is the case, we’ll let you know our reasons.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or to object to the use of your personal information at any time
- Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it.
If you have any questions or concerns about this privacy notice or your data protection rights, please contact us using our details set out at the beginning of this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner's Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.
V1.1 accurate 07/03/2023