InsureApp.com BV (“InsureApp”) takes your privacy very seriously and treats all your personal information with great care. In order to guarantee your privacy, InsureApp always acts in accordance with the Personal Data Protection Act (“Wet bescherming persoonsgegevens”).
A. Who is InsureApp?
InsureApp offers the Application with which your driving behavior can be analysed. Based on this analyzation InsureApp may provide certain benefits, such as specific services regarding insurance, prevention of damage and (lifestyle) coaching.
InsureApp, is a company with limited liability established and existing under the laws of The Netherlands, having its registered office in Nieuwegein and place of business in (3439 NK) Nieuwegein, the Netherlands, at Newtonbaan 3.
The manner in which your personal data are used has been reported to the Dutch Data Protection Authority.
B. Information collected through the Application
In order for you to download and install the Application, InsureApp requires you to provide personal information such as your name, date of birth, gender, address, e-mail address and (optional) your Social media ID.
Information on using the Application
After verification of your e-mail address, InsureApp will store an InsureApp ID number which it will use for automated profiling as explained in section C below. In addition, InsureApp will collect and process your real-time location based on information provided by your device operating system (‘OS’) your type of device, type of OS, type of mobile browser, information on your use of the Application, accelerometer data and gyroscope data.
Further, depending on your device make and type and your permissions, InsureApp may also collect the following data supplied by the device’s OS: camera access, activity information, step detection and step count, Bluetooth information and battery information.
Insurance agreement information
The application offers the opportunity to enter into an insurance agreement with InsureApp. If you enter into an insurance agreement with InsureApp you will be requested to submit additional information including but not limited to your car details (including your license plate) and information regarding to your claims history.
In order to improve its profiling algorithms, InsureApp may request and collect your feedback on assumptions made by InsureApp based on the collected information.
C. Purpose of collection and use of information
InsureApp uses your information for the following specific purposes:
- to allow you to use the InsureApp
- to build driving scores that may allow InsureApp to detect your driving behavior and map your driving routes
- to build a personal profile based on your account details, your use of the application and, if you enter into an insurance agreement through the application, the data relating to the insurance agreement.
- to send you adequate information regarding the Application
- in order to perform the insurance agreement if you have entered into one through the application
- to send you information regarding targeted marketing
- respond to your comments and problems
- for InsureApp data analysis and product development
- to investigate potentially unlawful use of the Application
InsureApp only collects personal information that is adequate, relevant and limited to what is necessary for the above purposes (data minimization).
The personal data provided by you upon creating an account, the information you add to your account during your use of the application as well as the information collected through your use of the application will be used to build a personal profile.
This profile can be used to provide you with commercial offers and advertisements, including but not limited to offers for the insurance agreements of InsureApp, lifestyle coaching and damage prevention. InsureApp interacts with the user to encourage low risk and healthy behaviour. For instance, when phone usage is detected while driving, a notification is send to the user. It is therefore possible that the insurance agreement offered by InsureApp is (partially) based on the profile created in the application.
Once you enter into an insurance agreement with InsureApp, the data provided in relation to the insurance agreement will be combined with your profile. Based on your profile InsureApp may offer you other insurance offers. furthermore, your profile may be of influence on the conditions of the insurance agreement. In addition, InsureApp offers relevant insurances at the right time, for instance a notification is send to the user to enable travel insurance when at the airport.
D. Third party recipients of information
InsureApp may disclose your personal and non-personal information to third party recipients such as:
- InsureApp’s service providers, such as its offshore development hubs and service providers, hosting providers, and providers of data analysis, IT services, and other similar services requested by InsureApp
- Other recipents based on legitimate interests as permitted under applicable law
- A third party as required by applicable law, to comply with legal procedures, to respond to requests from public authorities, to enforce this policy and to protect InsureApp’s rights
- A third party in the event of any merger, sale or transfer or other disposition of all or any portion of InsureApp’s business, assets or stock in which said third party is involved
Transfers only relate to personal information which is adequate, relevant and limited to what is necessary in relation to the purpose for which it is transferred.
Other than as set forth above, InsureApp will not transfer any of your personal information to third parties without your explicit consent.
F. Security, reliability and retention of information
InsureApp has implemented appropriate technical and organizational measures (such as explicit opt-in and pseudonymisation), which are designed to implement data-protection principles (such as data minimization) in an effective manner and integrated the necessary safeguards into the processing in order to protect information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal information, and against all other unlawful forms of processing.
InsureApp takes reasonable steps to ensure that any personal information in its possession is accurate, current and reliable for the purposes set out above.
All personal data collected in the European Economic Area (EEA) will be stored and processed within the EEA. InsureApp will only retain your personal data for the minimum period necessary to serve the purposes as set out above, unless a longer retention period is required by law. Non-personal information may be retained without limitation in time.
G. Your rights
In respect of the collection and use of your personal information, you may
- ask InsureApp whether it processes personal data about you, for which purposes, the categories of personal data concerned, to which recipients the information has been disclosed, where possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine that period)
- inqure with InsureApp about the appropriate safeguards relating to the transfer to a third party
- ask InsureApp a copy of the personal data undergoing processing and have it rectified
- object against the further processing and request erasure of your personal information on legitimate grounds
- request that the processing of your personal information is restricted by InsureApp
- request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you
In order to do so, you should send InsureApp a letter on the address provided below or an e-mail to email@example.com with a copy of your identity card or other proof of your identity. InsureApp shall respond within 4 weeks to your request. If InsureApp decides to deny your request, it shall inform you on the grounds of this decision.
3439 NK Nieuwegein
You may also lodge a complaint with a supervisory authority in case of breach of the applicable privacy laws by InsureApp.
You may at any time immediately stop any collection and processing of personal data by InsureApp by uninstalling or deleting the Application. Uninstalling the Application will also delete the InsureApp ID number from your mobile device. If you want to keep the Application but stop the collection of your real-time location data, you may opt-out through the OS settings of your device. Please be aware that such opt-out may result in your profile becoming inaccurate and unreliable.
If you have any questions, please do not hesitate to contact us via firstname.lastname@example.org.
Last modified: May 01, 2017