This Privacy Notice describes how Altelium Ltd (“Altelium”, “we”, “us”) collects, stores and processes your personal data in connection with the provision of our Services through our website, products, software and other platforms (jointly “Altelium Services”).
Altelium is the data controller in the processing of personal data in connection with the provision of the Altelium Services to you. Altelium is registered with the Information Commissioner’s Office under registration number ZB047310.
Altelium takes your privacy very seriously. We understand that some of the information we collect is sensitive and personal. We comply with all applicable Data Protection regulations including, but not limited to, the EU General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018 incorporating UK GDPR. We handle and store personal data with care and only process the necessary data to provide you with a high-quality service and to provide you with access to competitive insurance products, all in accordance with this privacy notice.
If you purchase Altelium Services through our website, our website terms and conditions, which can be found here: https://altelium.com/terms-and-conditionswill apply to the sale of such Services, alongside this privacy notice.
Certain aspects of the Altelium Services may be provided to you through any of our partners (“Partners”) in connection with the provision of the Partner’s service (“Partner Service”) to you. Each of Altelium’s partners also processes your personal data as a data controller and is responsible for its own data processing. For information about how a partner processes your personal data please see relevant privacy policies or contact the partner directly. Altelium takes no responsibility for how the Partners handle your personal data in their capacity as a data controller of that data.
Please note that, if you purchase an insurance product from one of our Partners, the contract for the sale of insurance products will be between you and our Partners and Altelium shall have no liability or responsibility to you in respect of that contract.
Information we collect from you
The primary source of the personal information we will have about you will be from the information you provide to us when you create an account with us or when you apply for an insurance product through our customer portal. When you complete your application, you may be asked for additional information. We may also obtain personal data about you from third parties, such as credit reference agencies, and government bodies, if any of the services you request from us require us to undertake searches against you. We will make it very clear to you that this is what we are doing, and you are free to require that we do not do this, but this may mean that we are unable to provide you with some, or all, of our services.
Your personal data is processed in order to achieve our commitment to you and give you the services that you expect. We do not store your personal data longer than is necessary to fulfil the purpose with the processing. We have a data retention policy that details how long we will keep the data we collect, a copy of which will be provided on request.
The personal data we collect and process differs depending on the Altelium Service we provide to you and which, if any, Partner Service you choose to use.
The information we may process about you includes the following:
|Insurance Products||EV Insights|
|Individual details, i.e., Name, address, contact details (e.g. email, home address and telephone numbers).||Individual details, i.e., Name and email address.|
|Background details, i.e., Background check information including compliance and criminal checks*, company registration details.||Vehicle details, i.e., Make/Model technical details, VIN, registration number, odometer and range estimates.|
|Financial details, i.e., Bank account or payment card details.||Vehicle connection details, i.e., log on credentials to establish connection to your vehicle to retrieve statistics.|
|Risk details, i.e., Credit history, credit score, financial information, business activity, Policy information .||Statistics, i.e., charge rate, state of charge, battery level, odometer and range.|
|Claims, i.e., current and previous claims, criminal, and other special categories of personal data*.|
Items marked with a * are special category personal data and will only be collected by us where relevant, and where required by us and/or our Partners to enable us and them to provide you with a quote for an insurance product or make a claim.
In some instances, we are provided with information from our Partner(s) through the Partner Service. This is information that you have already provided to our Partner and that is necessary for us in order to provide the Altelium Services to you.
If you are providing information on behalf of someone else, you confirm that they have consented to the sharing and processing of this personal information. Also, that you have informed them of our identity and have provided them with a copy of this privacy notice.
How and why we use this information
To make use of your data we must have a ‘lawful basis’ for doing so and must outline which lawful basis we are using to process your data.
When you are providing us with your personal data to enable us to provide the Altelium services to you, we will use the lawful basis of ‘contractual obligation’.
When we are sending marketing communications with you, the lawful basis will either be ‘legitimate interests’ or, where you have specifically asked to us send these communications to you, the lawful basis will be ‘consent’. Where you have given consent you can withdraw it at any time. You may also unsubscribe from any marketing communications by clicking on the ‘unsubscribe’ link on all of our marketing emails and we will remove you from our mailing list.
We may also use your personal data to assist in the improvement of the Altelium Services and we will do so under the lawful basis of ‘legitimate interest’.
We also use your data in order to perform product and customer analysis, statistics profiling, and business and method development. Furthermore, data may be processed for the purpose of ensuring that we have performed the Altelium Services correctly. It can also be necessary to process personal data in order to provide customer support to you or our Partners.
We will also anonymise and aggregate your data and compile it with other data for the purposes of analysing trends and preparing insights.
Who we share your information with
To deliver Altelium Services, we may need to disclose your personal data to a number of Partners or Partner Services you are using. These include insurers, reinsurers, brokers, reinsurance brokers, other intermediaries, claims handlers, premium finance providers, outsourcers, sub-contractors, agents and service providers, professional advisers and auditors. The Partners with whom we share your data are required by law and contractual undertakings to keep your data safe and confidential. The Partners use and disclose the confidential information for purposes of provision of Altelium Services and in accordance with the applicable legislation.
In addition to the above, we may share and combine your data with Alt IMS Services Ltd and Helestia Ltd, including information on quotes, insurance policies and claims. This information is used to:
- Identify products and services that could be of interest to you. Including tailoring and packaging our products and services to lead to pricing and/or available discounts; and
- Perform marketing campaigns and customer research.
We and/or other parties to whom we disclose personal data may use your information for research and analysis.
It is possible in some circumstances we may transfer some of your personal data outside the UK and EEA. In such circumstances, we take appropriate safeguards to require that your personal data will be processed and remain protected in accordance with applicable data protection laws (e.g., UK international data transfer agreement (IDTA), and the European Commission’s standard contractual clauses).
How long we keep your data
We will only keep your personal data as long as is necessary for the purpose for which we originally collected it or where we are required to keep your personal data for legal or regulatory reasons. Thereafter the data will be deleted, anonymised or pseudonymised in accordance with our data retention policy.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your data protection rights
As a data subject, you have rights related to the processing of your personal data. The rights you have depend on the lawful basis we are using to process the data. An overview of your rights is below.
- Right to be informed: You have the right to be informed about the collection and use of your personal data.
- Right to access: You have the right to view and request copies of your personal data.
- Right to rectification: You have the right to request inaccurate or outdated personal information be updated or corrected.
- Right to be forgotten/Right to erasure: You have the right to request your personal data be deleted. Note that this is not an absolute right and may be subject to exemptions based on certain laws.
- Right to data portability: You have the right to ask for your data to be transferred to another controller or provided to them. The data must be provided in a machine-readable electronic format.
- Right to restrict processing: You have the right to request the restriction or suppression of your personal data.
- Right to withdraw consent: You have the right to withdraw previously given consent to process your personal data.
- Right to object: You have the right to object to the processing of your personal data.
Further information about your rights can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you would like to exercise any of your rights or if you have any questions or complaints with respect to our use of your personal information, please contact the data protection officer, Thomas Kazas, at the following email address: email@example.com
Alternatively, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). More information can be found at www.ico.org.uk