fresh Insurance Services Group Limited (fresh/We) is are registered with the Information Commissioners Office (ICO) for data protection purposes under reference Z7026341. We trade under the brand names Ladybird Insurance, First Insurance (including First Van), Autosaint Insurance, Motor Trade Direct, Insure OK and fresh Home. For the purposes of this notice personal data or data may include both personal data, such as your name, address, date of birth and claims history and “special” categories of data such as information about offences, criminal or motoring convictions and medical conditions.
We are committed to ensuring that your privacy is protected. Should we hold or use your personal data, you can be assured that it will only be used in accordance with this privacy notice. You must have received the consent of any third party named on your insurance policy to provide their personal data to us and you should show this notice to them. This policy should be read in conjunction with the Terms of Business that relates to your insurance policy with us. fresh may change this policy from time to time, however we are not obliged to give notice of the changes so you should check our websites or contact us to ensure you are referring to the latest version.
Information about you may also be obtained from credit reference agencies such as Experian or Call Credit, debt tracing agencies, the Claims Underwriting Exchange (CUE), the Motor Insurance Bureau (MIB) and the Driver and Vehicle Licencing Agency (DVLA).
We may request Driving Licence Numbers from all drivers as part of your application for motor insurance, if you add an additional driver to the policy mid-term or when you renew your policy. We may use your Driving Licence Number to obtain information from the Motor Insurers’ Bureau (MIB) Hub about your licence using the MyLicence service. For details about how the MIB will treat your data when using the MyLicence service, please visit here. To view your driving licence data please visit here.
fresh will use your data for providing an insurance quotation, managing and administering your insurance policy, assisting with any claims, responding to complaints, policy enquiries, arranging premium finance or managing outstanding balances.
If you are insuring a vehicle or vehicles details of this/these and the insurer have to be passed to the Motor Insurance Database (MID) run by the MIB. This is to demonstrate that you have insurance cover on the vehicle(s) as required under the Road Traffic Act 1988 (RTA). This is normally done by the insurer but on occasion we may also do this on their behalf.
We may also use your personal data for analytical purposes, sometimes referred to as ‘Big Data’. For example, we may analyse how many claims happen in a particular postcode or if some types of people are more likely to be involved in accidents than others. Using your data in this way assists us in providing our customers with the lowest premiums possible.
We may ask you to participate in surveys that assist us in developing and improving the service we offer. We may use your personal data to keep you informed about other products and services that we have available and where we have your consent to do so we may share your data with other carefully selected financial services companies to allow them to contact you about products and services that may be of interest to you. You can withdraw consent at any time by contacting us using the information in the contact details section or using the ‘unsubscribe’ option in any marketing emails we send to you.
If your insurance policy requires the installation of a telematics box, we will use the data provided by the box to monitor your driving behaviour. Further details surrounding the manner in which we use your telematics data can be found below. We may also use location data from your telematics box which may be used to identify the location of the vehicle and the address at which your vehicle is regularly parked overnight. We may also provide your name, address and contact details to a third party contractor in order to arrange delivery and/or fitting of the telematics device.
In order to prevent and detect insurance fraud and other crimes, and aid in the prosecution of offenders, we may use your personal data to -
Your personal data may also be used to allow us to fulfil our legal or regulatory responsibilities, this may involve sharing your personal data with authorities such as the Financial Conduct Authority (FCA), The Information Commissioner’s Office (ICO), police and governmental agencies if requested and required to do so.
If you are unable or unwilling to allow us to use your data in line with this privacy notice, we will be unable to enter into a contractual relationship with you. Data obtained if a telematics box is installed as a condition of your policy.
It is very important that you read this section so that you understand how fresh use the data collected by the telematics box. The telematics box does not determine who is driving the vehicle so you must show this notice to any named driver on your insurance policy and any other person who may drive the vehicle under their own insurance (where their policy permits this).
For the purposes of providing you with insurance, it may be a term of your policy to have a telematics box fitted to your vehicle to record information about your driving style. From the date of installation (or reactivation if the vehicle is already fitted with a suitable telematics box), we will use the telematics box to capture data from your vehicle. An electronic data feed will translate the GPS (Global Positioning System) co-ordinates from the box into a specific location which will provide detailed information including speed, braking/acceleration, cornering severity and physical location at any specific time. This information will be used to build up a profile of how, where and when your vehicle is driven and where it is parked overnight. This data will be processed by the telematics box service provider and their agents (and where necessary by us and our agents) which will converted into the scoring provided on your web based ‘dashboard’. This data is used to administer your insurance policy in line with the terms disclosed when the policy was purchased. It may also be used to verify that the vehicle is being used in the manner you have stated and is being kept at an address disclosed to us.
fresh takes the security of your personal data very seriously and have a ‘data protection by design’ philosophy to the protection of your privacy. In order to provide our range of products and services to you, it is necessary to share your personal data with third parties. We always ensure that the required safeguards are in place before sharing your data outside of fresh, its parent company (Vantage Holdings Limited) or any related company. On occasion, it may be necessary to transfer some of your data outside of the EU, but we will only do so if we have a contractual agreement with that company to protect the data to the same levels as we would and the country in which they are domiciled allows them to offer such protection. We may utilise US companies that are members of the Privacy Shield scheme which affords you the same protection to you data as you would get within the EU. More information on Privacy Shield can be found here.
The following outlines who we may share your data with and the circumstances in which we would do this:
If you request a quotation
If you take a policy through us
fresh will only use and store your personal data if we have a legal basis for doing so. It is your right as the subject of this data to be informed what the legal basis is for each type of processing that we undertake.
If you decide to take a policy with us, we will retain your personal data for seven years from when your policy expires. We will also retain telephone call recordings for up to seven years. Where you have approached us through a price comparison website and we provide you with a quotation but you decide not to go ahead, we will retain your personal data relating to that quotation for no more than 120 days. Where we have obtained your personal data directly or via a third party – for example another insurance broker or a marketing firm and we have your agreement to contact you at your next renewal, we will retain data for up to two years from your next renewal date.
If your insurance is an employer’s liability policy, we will retain the details of this policy for at least 60 years. This is ensure that the details are available to you should an employee lodge a claim against you far into the future, such as may be the case for an industrial disease where symptoms may not present themselves for many decades.
You have the following rights in relation to the data we hold about you, however some of these rights may not apply in certain circumstances – details are noted below. fresh have strict internal processes in place that ensure your rights are upheld and that any requests you make in relation to these rights are responded to within 30 days of you making it.
You have the right as a data subject to be informed in a clear and precise manner about the data we hold about you. Within this privacy notice we detail the nature of this data we hold, the reasons we hold it, how this data is used, who we will share this data with, how long we will retain your data and the rights you have in relation to your data. If you require any further information, you can contact us using the details in the contact us section.
In order to demonstrate the legitimacy of the personal data we hold on you, its accuracy and the lawfulness of the processing we undertake, you have the right to request a copy of all data we hold about you. You can request this information free of charge using the details below in the contact us section. We will provide a copy of all personal data we hold about you within 30 days of you making this request.
You have the right to ensure that all data we hold on you is both accurate and complete. If you are concerned that the data we hold about you is inaccurate or incomplete when considering the purposes for which your data is being used, you can ask us to rectify this. To do so, you should contact us using the details below.
You have the right to request that all of the data we hold on you be erased from our systems. We may only be able to comply with this request in specific circumstances. This request would also apply to any third party whom we had shared your data with, and we would notify them accordingly if your request was valid. We will not be able to erase your data in all circumstances. For example, we would not be able to erase data that is being processed for the purposes of administering a live or lapsed insurance policy unless policy has been lapsed for seven years or more. This is because we have a legal obligation to retain this data for the defence of legal claims should a third party make a claim against your policy. If you require any further information, or you wish to exercise your right of erasure, you should contact us using the details below.The right to restrict processing
You have the right to restrict our processing of your data under the following circumstances:
If you wish to exercise your right to restrict processing, you should contact us using the details below.
Where we are processing data under the basis of contractual performance or consent you have the right to request that we provide your data in a machine readable format that you can then share with other businesses or in any other way you see fit. You have the right to request that we transfer your data to third parties directly for them to use as you see fit. We are able to provide your data either as an .XML file or a .CSV file. You are able to utilise your data in this way by contacting us using the details below.
You have the right to object to your data being processed. The right to object for direct marketing purposes or profiling of your data for the purpose of direct marketing is absolute and we must cease the processing of your data for these purposes. However for other processing the right to object is not absolute and there may be some compelling reason why we need to continue processing your data. Please contact us using the details below if you want to exercise this right.
You have the right to request human intervention into any process involving automated decision making where this results in a legal implication to you. This right would not apply to underwriting decisions or to applications for credit made on our website or internal system as this automated decision making is required for entering into a contract with us. Currently, we do not use automated decision making for any other functions, but if you have concerns regarding this, please contact us using the details below.
You have the right to complain about the use of your personal data – in the first instance please contact us using the details below. Our complaint handling procedure is available upon request or can be accessed from the fresh websites. You are also entitled to complain to the Information Commissioner by writing to -
Information Commissioner's Office
Alternatively, you can access their website here.
fresh will always endeavour to ensure that your personal data is accurate and up to date. If you notice that any information on your policy documentation is incorrect or if any of your personal data changes, for example you move house, change your vehicle or occupation or you bank details, please contact us to make us aware of these changes.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic contractual and managerial procedures to safeguard and secure the data we hold and use.
By running a quotation on any of the fresh websites, you agree that we may call you to discuss the quotation, regardless of whether you chose to proceed with it.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. We use session cookies on our websites. We will use the session cookies to keep track of you whilst you navigate the websites.
We use Google Analytics to analyse the use of our websites. Google Analytics is a web analytics tool that helps website owners understand how visitors use with their website; this is also the only cookie we use on our sites. Google Analytics uses first-party cookies to track visitor interactions. User data gathered in Google Analytics can be analysed to help us to improve our sites.
For our reporting needs as well as system administration we may gather data about your computer which can include your IP address, operating system and browser type. This is statistical data about our users’ browsing actions and patterns.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking, Tools>Internet Options>Privacy and then selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including ours.
We provide links to third party websites as part of our service to you. We accept no responsibility for any statements, information, content and products associated with these third party websites. We accept no liability for these third parties for any viruses or anything else that could be infectious or destructive.
Postal address: The Data Protection Officer, fresh Insurance Services Group Limited, Burnt Meadow Road, Redditch, Worcestershire. B98 9PA Email: firstname.lastname@example.org Telephone: 0344 557 8400