Data Protection

This notice contains important information about the use of your personal information. Please make sure you read this notice carefully. By taking out this policy, you confirm that we may use your personal information in the ways outlined in this notice. As the terms of this notice will also apply to anyone else insured under your policy, you should show this notice to anyone else whose name you give to us, in connection with your insurance policy.  

Who we are

We are Aioi Nissay Dowa Insurance Company of Europe SE.

In this section, ‘we’, ‘us’ and ‘our’ refers to Aioi Nissay Dowa Insurance Company of Europe and any holding or subsidiary companies, including but not limited to Toyota Insurance Management SE.

If you want to know more about the Aioi Nissay Dowa Europe group please go to https://www.aioinissaydowa.eu/en/our_organisation.cfm

When you apply for motor insurance, your data will be collected and used by Lloyd Latchford Group Limited who arrange and administer your policy on our behalf and FMG Support Limited who administer claims on our behalf. The use of your data in relation to the arrangement and administration of this insurance policy will be governed by their privacy policies which you should read:

• http://www.lloydlatchfordgroup.co.uk/about/privacy-policy/
• https://fmg.co.uk/privacy-statement/

You can ask for further information about our use of your personal information or complain about its use, by contacting the Data Protection Officer at: 52-56 Leadenhall Street, London EC3A 2BJ or contacting us at DPO@toyota-im.com.
You should also read all our privacy policy as this details how we will use your data for activities not related to the administration or arrangement of your insurance policy i.e. the use of your data for marketing purposes etc.

Your Information

In order for us to provide and manage our services to you we will ask you to share your personal information with us. The information we collect about you varies depending on your particular circumstances and requirements and may include:

• general information about you such as your name, address, e-mail address, contact details and date of birth;
• details about the vehicle you want to insure and named drivers;
• your claims and credit history;
• any criminal offences
• financial details, such as bank account and card details;
•  special categories of personal information (previously known as ‘sensitive personal information’), such as details regarding your health.
• information about your use of our website (IP address)
• Your marketing and communication preferences

How we collect your data

We may collect personal information from the following sources:

• you or someone connected to you as part of a quotation or claim;  
• publicly available sources of information, such as social media;
• third party databases made available to the insurance industry as well as databases where you have given your permission to share information with a third party like us;
• Information through “Cookies” and other similar technologies (e.g. pixel tags or links);
• our website, we record your computer’s IP address when you visit our website.

If you have provided information to us about someone else, you would have confirmed that you have the consent of these individuals to share their personal information with us.

How we use your personal information

We and/or our carefully selected third parties, associated companies, introducers, intermediaries and reinsurers, may collect and use your personal information to:

• assess your insurance application and arrange your policy;
• manage your insurance policy including claims handling and issuing policy documentation to you; and
• provide you with the services described in your policy documents.

Without the collection of this information, we will be unable to assess your application and/or provide claims services.  
We may process your information for a number of different purposes. For each purpose we must have a legal ground for such processing and for special categories of personal information, we must have an additional “legal ground” :

• We will use your special categories of personal information and any criminal offences in order to provide you with a quotation, price and/or the services set out in your policy documents. Where you have provided sensitive personal information about someone connected to you, for example named drivers, you would have confirmed that you have their permission to share this information with us.

We may share your information with third parties in order to communicate our similar products and/or services.

Automated Decisions

Our assessment of your insurance application may involve an automated decision. The decisions involve the use of systems, such as our price rating and acceptability tools, and are dependent on the information you provide us to produce a result as to whether we are able to provide a quotation and/or what the relevant price for your policy should be. If you object to an automated decision then then you can ask that a person reviews it.

Who we might share your information with

We may share your personal information with:

• other insurers, reinsurers, business partners, agents or carefully selected third parties providing a service to us on our behalf, such as claims handling and administrative services;
• organisations that have a specific role laid out in law such as statutory bodies and regulatory authorities;
• organisations where we have a duty or are permitted to disclose your information by law;
• fraud prevention agencies and operators of registers available to prevent fraud;
• credit reference agencies to check your credit history
• third parties to recover money you may owe us or to whom we sell your debt;
• other insurers, brokers or intermediaries to whom we decide to sell any specific insurance policies;
•  another company, if our business or part of it is bought or taken over by that company;
• Companies when we are trialling their products and services which we consider may improve our services to you;
• Other parties you have given us your permission to do so or there is sufficient reason to believe they are acting on your behalf.

Unless required by law, we would never share your personal data without the appropriate and necessary care and safeguards in place.

Sharing information to prevent fraud

In order to prevent and detect fraud, financial crime and anti-money laundering we may:

• collect personal information about you from databases as described and from publicly available sources;
• check your personal information against databases including no claims discount entitlement and driving licence records;
• share and check your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details will be passed to the fraud prevention agency. This information will be accessed and used by us, law enforcement agencies and other organisations to prevent fraud and money laundering. Other organisations may search the databases held by these fraud prevention agencies when you make an application to them for financial products. The information we share may be used by those companies when making decisions about you. We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies;
• share your personal information with operators or registers available to the insurance industry to check information you provide. These include the Insurance Fraud Bureau, Claims and Underwriting Exchange Register and Motor Insurance Anti-Fraud and Theft Register. We may pass information relating to your insurance policy and any incident to the operators of these registers, their agents and suppliers;
• share it with the Motor Insurance Database (MID). (See below)

We will use any personal information obtained about you, or anyone you have provided us information about, to carry out the above profiling activity as part of our investigations into fraudulent behaviour. Should fraud be identified as a result of such profiling activity, this could result in the rejection of an application for insurance, a claim and/or voidance of your policy.

How we communicate with you about our  similar products or services

We will contact you, in order to communicate our products and/or services to you which we believe may be of interest to you and which relate to your general insurance needs.   You can ask us to stop sending you marketing messages by contacting us at any time.

Storage of your information

The personal information we and our carefully selected third parties collect from you may be transferred to, stored and processed outside the European Economic Area (EEA). We or our service providers may use cloud based computer systems (i.e. network of remote servers hosted on the internet which process and store your information) to which foreign law enforcement agencies may have the power to require access. We will not transfer your information outside the EEA unless it was to a country our information regulator has assessed as having adequate data protection laws, or we had taken all reasonable steps to ensure the firm has the necessary privacy and security controls in place to protect your information as if it were in the EEA. Our contracts with these firms will detail the necessary requirements to ensure your information is protected. We will assess these firm’s security arrangements from time to time ensuring that they are only using your information as agreed. Should you wish to obtain further information about the safeguards we have in place, please contact the Data Protection Officer.

Retention of your personal information

We will keep your information for as long as you are a customer.  After you stop being a customer we may keep your data for up to 10 years for one of these reasons:

• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons for example if there has been a claim involving a minor.

Your rights

You have a number of rights concerning the personal information we use, these include the right to:

• ask for access to and a copy of your personal information;
• ask us to correct or delete the personal information;
• ask us to restrict or object to the use of your personal information;
• where you have previously given us your permission to use your personal information, withdraw that permission. Where your permission is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you do not wish us to contact you again;
• complain to the Information Commissioner’s Office at any time if you object to the way we use your personal information. For more information please go to www.ico.org.uk;
• object to an automated decision including  profiling.

To discuss your rights or make a request, please contact the Data Protection Officer.
Please note that in some cases even when you make a request concerning your personal information, we may not be required, or may not be able, to honour it as this may result in us not being able to fulfil our legal and regulatory obligations or there is a minimum statutory period of time for which we have to keep you information.  If this is the case then we will let you know our reasons. 

Motor Insurance Database

Information relating to your insurance policy will be added to the Motor Insurance Database (“MID”) managed by the Motor Insurers’ Bureau (“MIB”). MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVANI, the Insurance Fraud Bureau and other bodies permitted by the law for purposes not limited to but including:

• Electronic Licensing;
• Continuous Insurance Enforcement;
• Law enforcement (prevention, detection, apprehension and or prosecution of offenders)
• The provision of government services aimed at reducing the level and incidence of uninsured driving.

If you are involved in a road traffic accident (either in the UK, the EEA or certain other territories), insurers and or the MIB may search the MID to obtain relevant information.
Persons (including his or her appointed representatives) pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.
It is vital that the MID holds your correct registration number. If it is incorrectly shown on the MID you are at risk of having your vehicle seized by the Police. You can check that your correct registration number details are shown on the MID at www.askmid.com

Changes to your information

Your privacy is very important to us. We promise to respect and protect your personal information and try to make sure that your details are accurate and kept up to date. You can help us do this by letting us know whenever your personal details change.

Dealing with others on your behalf

To help you manage your insurance policy, subjecting to passing security questions, we will deal with you or your husband, wife, partner or civil partner or any other person whom we reasonably believe to be acting for you if they call us on your behalf in connection with your policy.
For your protection, only you can cancel your policy or change the contact address.