This privacy notice gives you information about how Marshmallow Financial Services Limited (“Marshmallow” “we”, “our”, “us”) collect and use your personal data for Marshmallow Go.
If you would like to speak to our Data Protection Officer you can email dpo@marshmallow.co.
(together, “Marshmallow Go Data”).
Personal data means any data about an individual from which that person can be identified. When you opt into Marshmallow Go, we will collect the following types of personal data:
We will only use Marshmallow Go Data where the law allows us to. The table below explains the purposes for which we intend to use Marshmallow Go Data and the legal bases we rely on for each of these purposes. We have further identified and explained our legitimate interests for doing so. We use Marshmallow Go Data to:
Better understand how our customers drive so we can develop more accurate pricing in our insurance products.
Legitimate Interests - necessary to help us develop more effective pricing models.
Create risk scores about your driving and share these with you.
Legitimate Interests - necessary to provide you with feedback about your driving and give you the opportunity to improve your risk score.
Verify that the information you have provided us in relation to claims is correct for fraud prevention.
Legitimate Interests - necessary to ensure the prevention of fraud where you have made a claim.
Help with your claims process. This may include accident detection and location checks.
Legitimate Interests – (in the event of an accident resulting in a claim) necessary to help us verify the circumstances around the incident.
Automated Decision Making
Marshmallow Go Data will be used by us and our third party partner Sentiance to create a profile of your driving style. This is how we can provide you with driving scores and give you insights about your driving style.
Your driving score is affected by:
– how harshly you brake or accelerate
– how smoothly you corner
– how often you exceed the speed limit and by how much
– how often you use your phone while driving
– the environments you drive in
– the times of you day you drive
– how harshly you brake or accelerate
– how smoothly you corner
– how often you exceed the speed limit and by how much
– how often you use your phone while driving
– the environments you drive in
– the times of you day you drive
You can always improve your driving score by adopting positive driving behaviours which you can learn about when using Marshmallow Go.
Please note, Marshmallow Go Data will not be used to cancel or calculate renewal premiums for your existing policy with us.
We may share Marshmallow Go Data with other members of the Marshmallow Group and third parties outside of the Marshmallow Group to ensure that we can provide services to you as follows:
1. Our service provider Sentiance, who help us to generate and understand your driving score.
2. Marshmallow Insurance Limited and/or Wakam, the companies who underwrite our policies.
3. Partners who help us manage claims in the event of one. To see this full list, please contact us at DPO@marshmallow.co
Whenever we transfer your personal data out of the UK or EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used when we transfer your personal data out of the UK or EU.
Marshmallow Go Data will be stored alongside the personal data we process to underwrite your insurance policy. This is based on a statutory retention period of 7 years.
You can opt-out of Marshmallow Go at any time. However, any Marshmallow Go Data collected whilst you were signed up to Marshmallow Go will be retained for 7 years where you have purchased an insurance policy from us.
You can exercise the below rights in relation to your Marshmallow Go Data. However, there may be some instances where we cannot fulfil your request, either in part or fully. We have provided examples of where this may be the case below:
Request Deletion: You can ask us to delete the data we hold about you where:
(i) there is no good reason for us continuing to process it, or
(ii) where you are exercising your right to object to our processing (see below).
Data connected to insurance policies you’ve purchased with us will need to be stored for 7 years. This is based on a statutory requirement we have as an insurance company.
Where we have identified data in relation to potential fraud, we will retain information that is necessary to help us handle this.
Request a copy of your data: This is commonly known as a “data subject access request”. You can ask us to provide you with a copy of the data we hold about you and check that we are lawfully processing it.
We won’t include information relating to other people (including Marshmallow employees).
Data Portability: You can request for us to send your data to another organisation.
We won’t include information relating to other people (including Marshmallow employees).
Request restriction to processing: You can ask us to pause using the data we hold about you where:
- you want us to establish the personal data’s accuracy;
- our use of the personal data is unlawful but you do not want us to erase it; or
- you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
We will continue to process the data to enable us to store it.
Object to processing: You can object to us processing your personal data where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
We will consider and respond to all requests to stop processing where we use legitimate interests. If we find that your rights as a data subject are not overridden, we may not uphold the request.
Data rectification: If you find that any data we hold about you is incomplete or inaccurate you can let our Customer Operations team know on our Live Chat and we will update it.
In certain circumstances we may need to run additional verification checks about the contested data.
If you have any questions about this notice or want to make a complaint, please email go to our Complaints Policy section. If you're still not happy you can refer your complaint to the Information Commissioner's Office whose website is: www.ico.org.uk and phone number is 0303 123 1113. Our ICO registration number is ZA295898.
We keep this notice under regular review. This version was last updated on 15 February 2024.
