(V2.0 - 14th January 2025)
Please take time to read this document carefully as it contains details of the basis on which we will process (such as collecting, using, sharing, transferring) and store your information. You should show this notice to all parties related to your insurance arrangement. If you have given us information about someone else, you are deemed to have their permission to do so. This document should be read in conjunction with our Terms and Conditions document which is available on our website www.zixty.com and from within the Zixty app.
If you have any questions or need further information you can contact us using our chat facility either via our website www.zixty.com or in the Zixty app ("the app") or write to us at Zixty Ltd, 10 York Road, London SE1 7ND.
We, Zixty Ltd (Zixty, we, our, us), with whom you have arranged your insurance is an appointed Representative of Movo Partnership Limited, who are authorised and regulated by the Financial Conduct Authority. Their Financial Services firm reference number is 823503. You can check Movo Partnership Limited's permissions at https://register.fca.org.uk/s/ or by contacting the FCA on 0800 111 6768
Zixty Ltd will treat your personally identifiable information strictly in accordance with The Data Protection Act 2018 (DPA 2018) as amended on 01 January 2021 to reflect the United Kingdom's status outside the EU.
Further Information about data and its use can be found at the Information Commissioners Office: Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF. 0303 123 1113. ICO https://ico.org.uk/
We will ensure data is processed lawfully, fairly and in an open and transparent manner and ensure appropriate security measures are in place against unauthorised or unlawful processing or accidental loss, destruction or damage using appropriate technical or organisational measures.
As a processor, we operate strictly in accordance with contracts we have in place with our suppliers (e.g., Insurance Companies, Software Providers, and similar providers of services to us) which set out our relationship as a processor as required by The Data Protection Act 2018.
As a controller we in certain circumstances also determine the purposes and means of processing data; in particular via the data collected by the app.
We will collect personal data which will include a variety of information about you such as:
Zixty Miles is an optional service we provide through our Zixty app which allows us to carbon offset the miles you have driven during policy cover. It measures your mileage and generates a score based on your driving behaviour using data collected via the app. We will also provide hints and tips on how you can drive in a more environmentally friendly way.
Where you sign up to Zixty Miles we will collect, via the app information about your journeys such as:
We will also collect, where relevant to do so, information relating to you indirectly by reference to an identifier (e.g., your IP address, which is a unique number identifying your computer, laptop, smartphone, or similar portable device).
Where required and appropriate to do so, we will also collect more sensitive personal information (such as credit worthiness or historic associations with postal addresses).
In certain circumstances (e.g. when an Insurance Company or similar provider of services to us requires us to do so) we will collect information from a variety of different sources (e.g. publicly available sources, such as social media and networking sites; third party databases generally available to the financial services sector, and the wider commerce and industry including, claims management firms, loss adjusters and or other suppliers appointed in the process of handling a claim or credit reference and similar agencies), including information from you regarding your past policies.
We rely on our own legitimate interests for much of the data processing we undertake when providing a service to you, including the collection of your journey data from your smartphone, and using this information to calculate your carbon offsets and driving related scores.
We may process your personal data to:
Our assessment may involve an automated decision to determine whether we are able to provide you with an insurance arrangement. You can object to us using an automated decision (see the individual rights section) however in those situations it may prevent us from being able to provide you with insurance.
When a Zixty App user enables Zixty Miles in the app the following terms also apply. (full Terms and Conditions are available at https://www.zixty.com/terms-and-conditions/)
The Zixty App collects and transmits data on location and mileage driven. The app collects location data whilst you are driving even when the app is closed or in the background. This data is processed to help identify mileage driven and driver behaviour. We will communicate this information to you in the Zixty App.
For further information we may:
Raw Trip data is anonymised and retained indefinitely and may be used by our Telematics provider and their associated partners for the purposes of improving systems.
The below lawful bases are appropriate for our data processing activities. We will use information, including sensitive information, about individuals, and other parties related to our insurance activities, because it is principally:
The below lawful bases are appropriate for our data processing activities. We will use information, including sensitive information, about individuals, and other parties related to our insurance activities, because it is principally:
The below lawful bases are appropriate for our data processing activities. We will use information, including sensitive information, about individuals, and other parties related to our insurance activities, because it is principally:
Where we rely on legitimate interests in order to process your data, you may object at any time.
We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact Support using our Chat facility either via our website www.zixty.com or in the app, or write to us at Zixty Ltd, 10 York Road, London SE1 7ND.
We will not change the lawful bases for our data processing without providing you notice.
Please note that Insurers and other third parties we may share your data with will act as data controllers for that data they receive. If we cease to process your data for whatever reason, Insurers or third parties may be required to continue to hold and process your data for their own purposes and based on their own legitimate interests or other legal basis.
When processing personal data for profiling purposes undertaken as part of our activities, including those as a distributor of insurance we will ensure appropriate safeguards are in place, ensuring:
We will also use your information when there is a justifiable reason for doing so, such as compliance with legal obligation (e.g., for the prevention and detection of fraud and financial crime, which may include processes which profile you); and for the recording and monitoring of telephone calls from you to us for auditing reasons.
By collecting information regarding your current, on-going, and past insurance arrangements or policies we will use this to carry out research and analysis (including profiling) principally as part of the actuarial (but not limited to) activities we carry-out to provide insurance arrangements to you now and in the future.
We will do this in such a way, which involves large volumes of information being converted into statistical or aggregated data meaning a particular individual can no longer be identified. Some aspects of the research and analysis undertaken are separate from using your information directly in connection with your insurance arrangement but are compatible with our activities as a distributor of insurance.
We will share information, including sensitive information, about you, and other parties related to this insurance because it is necessary:
This includes sharing your information with carefully selected third parties providing a service to us or on our behalf, these include:
Unless required to do so by law, or for other similar reasons, other than those outlined (see sharing your information) we will never otherwise share personal information without good reason and without ensuring the appropriate care and necessary safeguards are in place; we will in any other event ask for your consent to share that information and explain the reasons.
We will only keep and or maintain information about an individual for as long as is necessary in providing our products and services or for compliance with a legal or regulatory obligation, including our legitimate interests or of a controller.
This means, we will only keep information that is necessary to deal with queries, claims and for compliance with legal reasons, usually for a maximum retention period of 30 days for quotations we may provide and 18 months for any app and account information provided by you, and or up-to a maximum period of 7 years after cessation of a product or service we have provided. Your account profile information is automatically captured as you complete the quote journey, which is used to speed-up completion of subsequent quotes.
Where we are required to retain information beyond this period (e.g., for legal reasons) we will ensure the data we retain is minimised (so, in the example given here, this would be limited to information which is adequate and relevant for legal reasons)
We will never knowingly transfer, store, or process information about you outside the European Economic Area (EEA). In any event, if we are compelled to transfer your information outside the EEA (e.g. because it is an insurance arrangement with an Insurance Company who is outside the EEA or part of a larger group of companies who pass information outside the EEA) it shall be in compliance with the conditions for transfer set out in the Data Protection Act 2018 and or restricted to a country which is considered to have adequate data protection laws, and all reasonable steps shall typically have been undertaken to ensure the firm has suitable standards in place to protect your information
You will be asked to accept cookies, which are small files of letters and numbers that are downloaded onto your computer when you visit our website. This will be clearly explained to you when you visit our website, and you will typically have to accept the cookies to benefit from all the services our website can offer.
Cookies are operated in strict accordance with Privacy and Electronic Communications Regulations 2011 (PECR) and are widely used by many websites and enable our website to remember your preferences, recording information you have entered.
These same rules also apply if you access or use any other type of technology to gain access to information stored electronically by us (e.g., the Zixty app using your smartphone or similar portable device).
You have a number of rights relating to the information we hold about you; these rights include but are not limited to:
You can request a copy of your personally identifiable information we hold by contacting us including via the app. You have a right to data portability, so we will normally, not only provide the information free of charge (however we may apply a charge where information requests are excessive) but we will provide that information in a format that is easily accessible, typically in a CSV format, should you require it to allow your information to be exchanged easily with other organisations.
For further information please contact Support using our Chat facility either via our website www.zixty.com or in the app, or write to us at Zixty Ltd, 10 York Road, London SE1 7ND.
We will always ask for your consent to contact you, including the method (such as by phone, chat via the app, email, push notifications, SMS text, or post) to tell you about:
We will typically ask for your permission when you first contact us. You are able to withdraw your permission at any time by using the app or where offered an unsubscribe link in the messages received. Note that any changes to your marketing preferences may take up to 48 hours to take effect.
We may make use of third party services to measure and monitor use of the Zixty website and/ or the Zixty App in order to ensure that we provide the best possible service - by understanding the way in which users navigate our website and app. This data is anonymised and aggregated, with no personally identifiable information transmitted, stored, or analysed.
14th January 2025