Marshmallow Miles - Privacy Statement

Last changed: August 2022

Our company details

We are Marshmallow Financial Services Limited (“we”, “our”, “us”) and operate under the name of Marshmallow.We’re registered with the Information Commissioner’s Office under number ZA295898.We’re authorised and regulated by the Financial Conduct Authority under number: 797672

Contact details of DPO

If you would like to speak to our Data Protection Officer you can email dataprotection@marshmallowinsurance.com.

What information we hold about you

These are the types of information we will receive when you use a Marshmallow Miles product:

- Driving behaviour information (acceleration, braking, cornering)
- GPS location
- Mobile phone use (we will only know if you’ve been using your phone while driving)
- Time and date of trips

What other data do we use?
We will also use personal data to provide you with an insurance policy in line with the information set out in the main section of the privacy notice.

Purposes of processing your data and our lawful basis

What we do with the data
Our lawful basis for this
What’s the basis for this?

1. To better understand how our customers drive so we can build fairer pricing in our insurance products.

Contractual

We want to provide our customers with insurance prices that are fairer and more accurately based on how they drive.

2. Create risk scores about your driving and share these with you.

Contractual

This allows us to provide you with feedback about your driving and allows you the chance to improve your risk score. This is at the core of our Marshmallow Miles product.

3. To create and share risk scores indicative of your driving behaviour before your policy starts.

Legitimate interests

This provides you with an opportunity to get to grips with the app and how your driving behaviour affects your risk score.

4. Your driving data may be used to manage your policy if we need to intervene based on extreme and harsh driving scores.

Legitimate interests

Where we have identified driving events that clearly show dangerous driving habits or anything that breaks the law we have the right to cancel the policy.

5. Verify that the data you have told us about is correct for fraud prevention. This includes mis-representation about your details.

Legitimate interests

As an insurance company we take measures to reduce potential fraud.

6. To help with your claims process. This may be accident detection and location checks.

Legitimate interests

We can use data collected from Marshmallow Miles in the event of an accident to help us verify the circumstances around the incident.

Companies we share the data with

1. We use a company called Sentiance to help us understand your driving score.
2. We send your driving level (magician/pro/rising star) to boomf, our marshmallow provider, so they can send you the right reward, but no information about your actual driving score. We will use your address in order to send these to you.

Retention period
Driving behaviour data will be stored alongside the data we receive to underwrite your insurance policy. This is based on a statutory retention period of 7 years.

UK GDPR Rights
You can exercise the following rights in relation to your Marshmallow Miles data:

What are your rights?
Examples of when we might not be able to uphold your request

Delete your data: You can ask us to delete the data we hold about you.

1. 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.

2. Where we have identified data in relation to potential fraud we will retain information that is necessary to help us handle this.

Get a copy of your data: You can ask us to provide you with a copy of the data we hold about you.

1. We won’t include information to relating to other people (including Marshmallow employees)

Move your data: You can request for us to send your data to another organisation.

1. We won’t include information to relating to other people (including Marshmallow employees)

Stop your data being used: You can ask us to put a pause on using the data we hold about you.

1. We will continue to process the data to allow us to store it.

2.If we need to continue processing your data so that you can continue using our products and services.

Object to processing: You can object to any direct marketing from us. You can also ask us to justify how our legitimate interests are balanced with your interests.

1. 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.

2. If we need to continue processing your data so that you can continue using our products and services.

Correct your data: If you find that any data we hold about you is inaccurate you can let our Customer Operations team know on our Live Chat and we’ll update it.

1. In certain circumstances we may need to run additional verification checks about the contested data. 

Right to lodge a complaint with ICO

If you have any questions about this Privacy Policy or want to make a complaint, please email us at help@marshmallow.com. 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.

Existence of ADM

The data we receive about your driving behaviour will be used by us and our third party partner Sentiance to create a picture of your driving style and subsequently your potential insurance risk. This is how we can provide you with driving scores and give you insights about your driving style.

If you want us to check whether an automatic decision made about you is correct then please contact us.