For the purpose of this policy “Data Protection Laws” means: all applicable laws in the UK relating to the control or processing of personal data and to data privacy, including but not limited to the Data Protection Act 1998 (or an enactment that replaces it, Privacy and Electronic Communications (EC Directive) Regulations 2003, the applicable legislation on the protection of data subjects with regard to the data processing of personal data, including the EU Data Protection Directive 95/46/EC, (as may be superseded by the General Data Protection Regulation) and/or other applicable data protection or any privacy legislation in force or adopted by the UK, including where applicable, statues, decisions, guidelines, guidance notes and codes of practice issued from time to time by courts, data protection authorities and other applicable regulators or authorities in the UK (or where relevant in the EU).
1. Who are we?
2. Information we collect or use in order to initiate or administer testing or related services:
a) make initial contact, invite you to the test and for general administration of the end user testing of the Beta App;
b) register you if you want to redeem an insurance discount based on your telematics score;
c) supply a cradle to you to attach your Device to when using the dashcam feature. This is done by Marketing Lounge an approved Aviva supplier, who have access to your personal information for this purpose;
d) we may also use your name, email and telephone number to register you to use Aviva Drive’s proactive claims response service in the event you select this service; and
e) for general promotions of products or services that form part of the Aviva Drive Proposition.
3. What information or data does the Beta App collect?
3.1 The Beta App collects personal information about you such as name, address, contact details and company car registration number, as well as diagnostic information and communications logs provided by the Beta App and Your Device on which the app is loaded. The Beta App also collects information about how you access and use the app, including Your device type, the amount of time you use the Beta App and your use of the app’s features.
3.2 Dashcam: The dashcam feature will access your Device camera to record audio and video, replicating the function of a wired dashboard camera.
You have the control to switch on or switch off the dashcam feature of the Beta App.
Further you can terminate any video or audio recording at any time through the functionality in the Beta App.
Where Beta App’s Aviva dashcam is active during each journey, it does not record it in its entirety. Recording occurs either when you manually choose to save a clip, or automatically if a collision is detected
When you elect to switch on the camera features of the Beta App, the App will capture the video footage of your journey. You acknowledge and agree that such footage may inadvertently capture:
a) sensitive personal data about you, for example, sound or images which reveal your religious beliefs, racial or ethnic origin, political beliefs or sexual life;
b) pictures and conversations of your passengers including sensitive data of your passengers. It is your responsibility to explain what information the Bet App collects to any passengers in your vehicle and to get informed consent from them before using the Beta App; and
c) potentially contain recordings of the commission of a crime (although this may not be evident at the time of recording as it may not be possible to determine whether an offence has been committed or not). In such cases it is your responsibility to comply with applicable law.
3.2.1 Further where you decide to submit video footage collected by the Beta App you expressly consent to your sensitive data (or that of your passengers) being processed by us or our service providers for the purpose of evaluating the Beta App or for responding to a claim you submit to us.
3.3 Sensors and GPS. Whilst the Beta App and your Device are running it accesses the sensors on your Device to record location information, direction, speed, audio and video in order to record your journeys. Your location will be tracked via GPS when a clip is saved. GPS tracking is constant and sent to us automatically. When downloading the Beta App or agreeing to participate in the end user testing , you will be required to provide explicit consent before we can track your location and process your sensitive personal data.
4. Collision detection:
This is achieved via a third party collision detection technology provided by Zen Drive and embedded in the Beta App. In the event of a collision the Beta App will automatically record 30 secs of footage before the collision and a further 30 secs thereafter (“Collision Recording”).
4.1 Collision Recording is triggered when the Device exceeds an undisclosed G-force threshold. Zen Drive collision detection technology deploys a algorithm that uses sensory data from your Device’s accelerometer, gyroscope and magnetometer to produce a reading of the collision. Two filters are applied to the result to prevent Beta App recording collisions in error. These include incidents where the speed immediately prior to the collision was below 20 mph, and incidents where the vehicle remained in motion at a consistent speed after the collision. If the collision triggers both these filters, four additional factors, including free-falling, severe hand braking, accelerometer spikes and stopping distance, are then also assessed.
4.2 If a collision is identified, Zen Drive receives:
• User ID (a randomly generated unique identifier for each user created by us.)
• Time stamp
• 100 Hz sensor data around a collision event (accelerometer, gyroscope, magnetometer
• 1 Hz GPS data (includes lat/long location of the collision, direction of travel, path prior to the collision, and raw speed)
4.3 Proactive claims response: Further when Zen Drive detects a collision, their collision detection technology is capable of producing an ‘actionable data object’. This object can be transmitted to our Motor Claims operational centre, who will proactively call the user to offer assistance. This feature is only eligible for Aviva motor policyholders, and will not automatically opt user(s) in. You are required to register for this service if you wish to receive the proactive claims response service.
5 The following list of data is collected or shared for the purpose of making claims under a Aviva motor policy:
• Driver name (Existing registration requirement in v.1.9)
• Email (Existing registration requirement in v.1.9)
• Phone number (New registration requirement for v.2.0)
• Collision ID (Zen Drive SDK)
• Time (Zen Drive SDK)
• Location (Zen Drive SDK)
• Map link (Zen Drive SDK)
6. Sharing footage
6.1 You may choose to share your dash cam footage in two ways.
a. The dashcam’s ‘share’ button provides native device sharing functionality that will allow the user to email their footage as an attachment, or send it via SMS as an attachment.
b. You have the option to ‘notify Aviva’ or capability to send dashcam footage to us at Dashcam@aviva.com mailbox as an attachment by email. There is an operational requirement that this mailbox should not become an additional channel for first notification of loss. Users are required to have reported a new claim and have a claims reference number before submitting footage. Data input as the claim reference number will be validated at the front end, ensuring it is the correct number of characters and follows the standard format. Claims reference numbers will not be authenticated against Guidewire or any other claims handling system. Data submitted to us via this mailbox will be subject to the virus scanning protocols as no-reply mailboxes for post submissions. Video files will be compressed using a proprietary algorithm developed within Aviva Drive and will be no larger than 10MB.
6.2 In the case of Section 6.1 (b) the automatically populated email will contain:
• Customer name
• Accident date
• Accident location
• Confirmation if data manually / automatically recorded
• Dash cam footage attachment
6.3 Upon receipt of the dash cam footage an automated response will be returned to the user, advising them that their footage will be processed. Motor’s Claims Innovation sub team will triage footage submitted to the mailbox and route it to the appropriate claims handler for processing. Correspondence not related to dashcam football submission will not be processed.
7. How and where is your information stored?
7.1 All data recorded by the dashcam will be stored locally on your Device. No dashcam footage will be sent to us from the Beta App automatically except in the case of collision data triggered by the Zen Drive technology. You may choose to send us data recorded by the dashcam to support an insurance claim at your discretion. Non Aviva customers will have limited capability to share their dash cam footage clips as attachments via email.
7.2 Zen Drive processes and stores certain collision data described in Section 4 in a secure manner on an AWS cloud instance located in California in the US. Such data is pseudonymised or presented in a manner that Zen Drive does not have access to directly identifiable information about any active user on its platform at any stage of the process. In order to ensure that such transfer of personal data to the US is secure and meet standards set out in Data Protection Laws, we have EU Model Clauses in place with Zen Drive for compliant data transfer and processing. No sensitive customer data will be shared with Zen Drive.
7.3 The data you send via email from Aviva Drive’s Azure database to an internal Aviva mailbox (Dashcam@aviva.com is accessible and administrable for the duration of the BETA phase by Aviva employees from the Claims Innovation team. As per section 7.1 (i) above, the packaging of this data will be conducted on your Device itself.
7.4 Users’ registration data will be stored in Aviva Drive’s Azure database. This registration and data storage process already exists in Aviva Drive App v1.9, and is already mandatory if the user chooses to claim their insurance discount after completing Aviva Drive’s 200-mile evaluation.
7.5 You may delete the information stored locally by the app at any time by deleting the files from your Device. Further you may request deletion of information you upload or share with us by contacting firstname.lastname@example.org .
8. How long will we keep your information?
The information you share is kept for the duration of the test period save that if you choose to use any of the information collected in support of handling an insurance claim we will only keep the information for as long as is needed for the purpose of handling your claim, in line with our claims handling policies and procedures. For most claims, this means we will keep your data whilst we assess your claim and for up to a year following your claim being rejected or settled, as the case may be. For certain types of claims, we may need to keep the information for longer, bearing in mind certain legal considerations. (For example, for claims involving a person under the age of 18 where a personal injury claim may arise, we will keep the information until 3 years after they turn 18, which could, in theory, be up to 21 years after the incident giving rise to the claim.)
9. How will your information be used?
9.1 You will be able continue to use Aviva Drive App v.1. 9 in its existing state without using its new dashcam, and to use dashcam without giving access to your Device’s microphone.
9.2 No dashcam footage will be sent to Aviva from within Aviva Drive automatically. Users may choose to send Aviva data recorded by the dash cam to support an insurance claim at their discretion. Non Aviva customers will have limited capability to share their dash cam footage clips as attachments via email.
9.3 Aviva will not use (or seek to use) end users’ data in any way other than in accordance with its usual claims handling policies and procedures where end users choose to send recordings to Aviva in support of an insurance claim. All META tag data will be automatically erased from any dash cam footage that is submitted by the user. The Beta App is provided to you as part of our end user testing. Therefore, we will not use any information collected by the Beta App for any other purpose unless you choose to send the information to us to support an insurance claim.
10. With whom will your information be shared?
9. Safeguarding Information
We use commercially reasonable methods consistent with applicable Data Protection Laws that are intended to safeguard your personal information. No data transmission over the internet can be guaranteed to be totally secure, however. Although we take steps to secure the information you provide to us, we cannot guarantee the security of any information you transmit to us or that we retain. You use the Beta app, and provide us with personal information, at your own risk.
Aviva UK Digital Limited is a company registered in England & Wales with company number 09766150 and a registered office at St Helen’s,
1 Undershaft, London EC3P 3DQ.
© Aviva 2017