Privacy Policy

1. General Information

This privacy policy (our "Privacy Policy") together with our User Licence Agreement ("ULA") octou.com/en/ula applies to Users' use of the application called “Octo U” (the “Application”), which is available on iTunes Store and Google Play and any services accessible through the Application as further described and defined in the ULA (the "Application Services").

Octo Telematics UK Limited with registered number 6408826 of The Oakley, Droitwich, Worcestershire, WR9 9AY ("Octo Telematics", "we" or "us") is committed to protecting and respecting the privacy of users of the Application and Application Services ("Users"). This Privacy Policy sets out the basis on which any personal data we collect from our Users, or that they provide to us, will be stored, processed and shared. Please read the following carefully to understand our views and practices regarding Users' personal data and how we will treat it.

2. Data Controllers

For the purposes of the Data Protection Act 1998 or similar applicable law consistent with EU Directive 95/46, Octo Telematics is the data controller controller for the data its collects and processes relating to use of the Application and Application Services by Users. Octo Telematics’ Partners (as defined section 4 below) are each the respective data controller for the data that they receive from Octo Telematics and process as explained in this Privacy Policy.

3. Type of Data Collected and Processed

We collect the personal data specifically and voluntarily provided by Users.

“Personal Data” is understood to be any information by which a living individual may be identified, such as the name and surname, user name, password, sex, email address, place of birth, country, region, city of residence, current geographical location and vehicle information, including make, model, year and vehicle identification number, of a vehicle being driven by a User. The provision and collection of Users' Personal Data is necessary in order to allow the Application and Application Services to function as described in the ULA – accordingly, it is requested of Users when they create an account.

To provide the Application Services, we need to collect data on Users' geographical location when they use the Application and the Application Services. For the Application to function properly, it requires the GPS technology and location services on Users' devices to be switched on and the Application granted permission to use them in order determine their current location. By downloading and using the Application, Users consent to their data being collected and used for this purpose. Providing the Application Services also requires that we collect data on Users' driving styles and habits (“Driving Behaviour”), such as sharp braking, sudden accelerations, cornering, vehicle speed), which are supplemented by contextual data (traffic, weather, time of day).

We also collect technical information, including the type of mobile device Users use, mobile network information, Users' mobile operating systems, the type of mobile browser used, time zone setting etc.

However, we will not collect or process sensitive data, which is to be understood as personal data that is capable of revealing Users’ racial and ethnic origin, their religious, philosophical or other types of beliefs, political opinions, membership of political parties, trade unions, religious, philosophical, political or trade union associations or organisations, as well as personal data capable of revealing Users’ state of health and sexual habits. Users are kindly asked not to provide us with their sensitive data.

4. Data Processing Methods and Purposes

The Personal Data provided by Users will be processed by automated means using software and other IT instruments in order to make the Application and Application Services available. The Personal Data requested from Users when they register to use the Application is necessary to enable them to use the Application and Application Services including to allow our insurance or other company partners (our "Partners") to provide the tailored marketing communications referred to below. If Users choose not to provide their Personal Data when they register to use the Application, they will not be able to use it.

5. Use of Personal Data for Creating Tailored Marketing Communications

The core functions of the Application and the Application Services are (i) the processing the Personal Data provided by Users for profiling purposes by analysing tastes, preferences, driving habits, consumption needs and choices (i.e. the level of satisfaction with the Application Services) and (ii) the processing of Users' Personal Data for profiling purposes such as collecting aggregate statistics on all Users of the Application, drafting of traffic models, analysis of consumer habits and/or choices as may be further described in our Frequently Asked Questions page octou.com. Our profiling activities use complex calculus algorithms that factor in Users’ age, location, model of vehicle, driving behaviour and vehicle performance such as harsh acceleration, braking, cornering, vehicle speed, time of day and traffic and weather conditions in order to generate Users’ personalised driving score. This processing is used in order to assess Users' Driving Behaviour and, more specifically, to allow our Partners to propose commercial offers for motor vehicle insurance policies or other Partner services consistent with Users' Driving Behaviour. By clicking the relevant tick boxes in the sign-up process, installing the Application and using the Application Services, Users agree that they provide their explicit consent to (i) our collecting, storing and processing of their Personal Data and Driving Behaviour for such profiling purposes and (ii) the sharing of their data to our Partners so that they may generate personalised marketing initiatives and other direct marketing offers which will be messaged to Users via email and other direct marketing offers. Octo may receive compensation from our Partners as part of our sharing User’s Personal Data and Driving Behaviour with our Partners.

By clicking the relevant tick box in the sign up process, installing the Application and using the Application Services, Users agree that they provide their express consent to our Partners’ processing Users’ Personal Data and Driving Behaviour that they may receive from us in order to generate personalised marketing initiatives and other direct marketing offers which will be messaged to Users via email and other direct marketing offers. If Users follow any links to our Partners, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Users should check these policies before they submit any personal data to these websites or use these services.

Users can withdraw their consent to allowing their Personal Data and Driving Behavior to be used for profiling purposes or receiving either marketing communications, at any time and free of charge, by deleting the Application from their device(s) on which it is installed or by contacting us at privacy@octou.com.

6. Interactions with the Social Networks

The Application may contain material and applications (“API” or “APIs”) which use data taken from Users’ social network accounts such as Facebook, Twitter, Google+.

An API may be created that allows comments to be posted directly on social networks on which the User is registered. When an API of this sort is used, personal data is transmitted to the social network’s website. Such data is regulated by the aforementioned social network’s data protection information notice. An API may also be created that permits the exchange of information and content concerning Users and their friends, their user IDs and other types of content taken from the social network that is being used. Such information and content shall not be acquired, unless Users give us their consent on the relevant social network’s website. If Users do give us such consent, the aforementioned information shall be used in accordance with both this Privacy Policy and also the rules on the APIs of the relevant social network.

7. When We Might Disclose Users' Data

Strictly for the purpose of providing the Application Services to our Users, we may disclose some or all of the data we collect from our Users when they download the Application or use the Application Services to our Partners (http://www.octou.com/partners/) for processing to allow them to generate the marketing communications that form a fundamental part of the Application Services. For the purpose of processing to generate customized marketing communications, our Partners will be acting as data controllers regarding the data received from us.

We may disclose Users' Personal Data and Driving Behaviour to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, which shall act as data processors regarding the disclosed data.

By downloading the Application and using the Application Services, Users also agree that we may disclose their Personal Data to certain third parties not referred to in this Privacy Policy, but we will only do this:

In order to:

8. Persons Tasked With Processing the Personal Data

Personal Data provided to us by our Users during their use of the Application or the Application Services may be accessed by staff who work for us or one of our suppliers that are in charge of processing the data. However, we will ensure that such access is limited only to those people who need access to it in order to provide the Application Services and for the purposes outlined in this Privacy Policy and in accordance with any specific consents provided to us.

9. Data Subject's Rights

The Data Protection Act 1998 gives individuals the right to access information held about them. Users' right of access can be exercised in accordance with that Act. Any access request may be subject to the advance payment of a fee of £10, to the extent permitted by applicable law. These sums are needed to meet our costs in providing Users with details of the information we hold about them.

10. Where We Store Users' Personal Data

The data that we collect from Users may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or for one of our Partners. By submitting their Personal Data, Users agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Users' data is treated securely and in accordance with the Data Protection Act 1998 and with this Privacy Policy.

11. How Long We Store Users’ Personal Data

Personal Data provided to us by Users will be retained for the duration of each Users’ use of the Application or the Application Services and for a period of one year after each Users’ last use of the Application, in order to allow the User to resume use of the Application. After one (1) year of nonuse, the User’s Driving Behaviour data is anonymized to disassociate it from User’s Personal Data and all Personal Data is deleted. If Users delete their profiles within the Application, all Personal Data is deleted immediately.

12. Changes to Privacy Policy

We reserve the right to change our Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to Users by e-mail or when Users next start the Application. The new terms may also be displayed on-screen and Users may be required to read and accept them in order to continue their use of the Application and the Application Services.

13. Contact Details

For any information or request on the protection of Users’ Personal Data, please contact: privacy@octou.com.