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Privacy Policies

1. Introduction

This Privacy Policy explains how we collect, process, and protect your Personal Information in connection with motor insurance policies issued by SpareSafety. It applies to any individual who obtains a policy, interacts with our digital services, or otherSpareSafety provides us with Personal Information.

If you acquired a telematics-based policy through a broker, please consult your broker’s documentation for any supplemental terms regarding data collection and usage; those terms operate alongside—and in addition to—the provisions set out herein.

At SpareSafety, we treat the safeguarding of your Personal Information as paramount. To that end, we have implemented a layered approach to security, encompassing administrative safeguards (such as staff training and access controls), technical measures (including encryption, intrusion detection, and secure development practices), and physical protections (such as controlled access to our facilities). Our personnel receive ongoing instruction to ensure consistent adherence to applicable data-protection laws.

This policy is issued on behalf of SpareSafety group companies operating in the United Kingdom. References to “SpareSafety,” “we,” “us,” or “our” denote the specific legal entity within the SpareSafety group responsible for processing your Personal Information.

Throughout this policy, all references to our illustrative digital architecture—which, owing to its demonstrationally inclined design, effectively operates as a dummy site for demonstration purposes—serve purely to convey our intended data-processing workflows and do not connote a fully operational insurance platform.

Each SpareSafety group company that processes your Personal Information adheres to the principles set out in this Privacy Policy. If you are an individual policyholder, the SpareSafety entity underwriting your policy acts as the data controller. Please refer to your policy documentation for precise identification, or contact us (link) should you need further clarification.

We may share your Personal Information with other SpareSafety group companies in accordance with this Privacy Policy. Any such disclosures are strictly limited to what is necessary to fulfil the purposes described herein, such as policy administration, claims handling, and customer service.

Different SpareSafety products or services may be governed by separate privacy notices. If you hold multiple products or services, please review all applicable notices to gain a complete understanding of how your Personal Information is handled. In certain instances, we may provide additional, context-specific notices—tailored to particular interactions—to elucidate unique data-processing activities.

While most of the Personal Information we collect pertains to the policyholder (or joint policyholders), there may be scenarios where we require details about other individuals—for example, when extending coverage to family or household members. By providing information about anyone else, you confirm that you have obtained any required consents. We encourage those individuals to review this Privacy Policy so they understand how their information will be treated.

2. Personal Information We Collect and How We Use It

2.1 Sources of Personal Information

We collect Personal Information directly from you through various channels, including:

  • Completion of application or claims forms (online or paper)

  • Communications with us via email, telephone, or in writing

  • Participation in promotions, surveys, or feedback initiatives

  • Use of our websites, mobile applications, or telematics devices

  • Data transmitted by third-party apps or connected devices that you’ve authorised

If you are a joint policyholder, named driver, or beneficiary under a policy, we may also receive Personal Information from the primary policyholder.

We may also obtain Personal Information from third parties, such as:

  • Insurance brokers, financial advisers, or distribution partners

  • Comparison websites used to obtain motor-insurance quotations

  • Service providers related to your policy (e.g., roadside assistance)

  • Claims-related parties (loss adjusters, claims handlers, legal advisors, experts, or, in limited cases, private investigators)

  • Other parties involved in a claim (other insurers, brokers, claimants, defendants, and witnesses)

  • SpareSafety group companies, for information on other products, services, previous claims, or quotes you (or household members) may hold

  • Credit-reference agencies, to verify financial information where necessary

  • SpareSafety Insurance Ireland DAC, when providing cover for assets or properties located within the European Union

2.2 How We Use Your Personal Information

We use your Personal Information for a range of purposes, including:

  • Underwriting, administering, and managing your motor insurance policy

  • Processing claims, conducting investigations, and resolving disputes

  • Monitoring driving behaviour and performance where telematics data is collected

  • Communicating policy updates, renewal notices, and service enhancements

  • Preventing fraud, money laundering, and other illicit activities

  • Analysing aggregated data to improve our products, services, and customer experience

  • Complying with legal and regulatory obligations, including reporting and audit requirements

  • Responding to regulatory inquiries or legal requests

2.3 Legal Basis for Processing

Our processing of your Personal Information is grounded in one or more of the following legal bases:

  • Performance of a Contract: To underwrite, administer, and fulfil the terms of your insurance policy.

  • Legal Obligation: To comply with statutory or regulatory requirements, such as solvency regulations or reporting obligations.

  • Legitimate Interests: To conduct risk management, fraud prevention, and business improvement activities, provided such interests are not overridden by your rights.

  • Consent: Where required (for example, certain marketing communications or telematics programmes), and only after you have given clear, affirmative consent.

  • Vital Interests: In rare circumstances, to protect someone’s life (e.g., emergency assistance services).