Marshmallow Technology Ltd, Marshmallow Financial Services Limited, Marshmallow Technology Hungary Kft, Marshmallow Credit Services Limited, Marshmallow Repair Limited and Marshmallow Insurance Limited (collectively referred to as “
Marshmallow, “
Marshmallow Group”, “
we”, “
us” or “
our”) are committed to maintaining the privacy and confidentiality of information you provide to us. This privacy notice sets out how Marshmallow uses and protects your personal data through your Marshmallow Move policy.
1. What personal data we collect about you
If you have the Marshmallow Move policy, we will collect your personal data. We may collect, use, store and transfer the below categories of your personal data in addition to the personal data we collect about you from our
main privacy notice:
- End user data and contact information - e.g. name, phone number, email address, other unique driver identifiers.
- Mobile phone data - e.g. mobile phone usage, IP address, operating system, version, model, battery levels, unique device identifiers.
- Telematics sensor data - e.g. accelerometer, gyroscope, barometer, magnetometer, tag anti-tampering.
- Driving data - e.g. geolocation, date, time, event-level information (e.g. harsh braking, speeding), distances.
- Inferences generated from the data above - e.g. assessments of driving style, risk characteristics or behaviour patterns.
The above personal data is collectively referred to as “Marshmallow Move Data".
2. Where we collect your personal data from
In addition to collecting your personal data when you purchase your Marshmallow Move policy with us (in line with our
main privacy notice), we will also collect the Marshmallow Move Data through the Marshmallow Move app and tag, which are operated by Cambridge Mobile Telematics. You can view Cambridge Mobile Telematics’ privacy policy
here.
3. Purposes of processing your data and our lawful basis
The UK GDPR requires us to have a legal basis for collecting and using your personal data. When we collect and use your personal data, we make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law.
Process / Purpose
What personal data we use
Legal basis
Provide you with your Marshmallow Move policy
Performance of a contract - to perform our obligations under your insurance contract with us
To check that you’re using your Marshmallow Move policy within the contract
Performance of a contract - to ensure you are performing your obligations under your insurance contract with us (e.g. to ensure that you aren’t using your vehicle for professional use)
Internally validate claims that you report or are reported against you
Legitimate interest - it is in our legitimate interest to develop and improve our services and products for your benefit
To assist in calculating your renewal price
Legitimate interest - it is in our legitimate interest to ensure we are charging you an appropriate price
We will also process your personal data in line with our
main privacy notice.
a. Disclosures within the Marshmallow Group
In order to provide our services, your personal data is shared with other companies in the Marshmallow Group. Your personal data may be shared for our general business administration, efficiency and accuracy purposes, for the prevention and detection of fraud, and also when we make changes to our group company structure.
b. Disclosures to third parties
We may also disclose your personal data to the below third parties for the purposes described in this notice:
The third party
What we share with them
Why we share it
Cambridge Mobile Telematics
To provide you with the Marshmallow Move app
To store and send you your Marshmallow Move tag
4. International transfers
Sharing your personal data both between the Marshmallow Group and to third parties may involve transferring your personal data to countries outside the EU and UK. To ensure that your personal data receives an adequate level of protection, we have put in place contractual obligations by using standard clauses issued by the UK Information Commissioner's Office (or other relevant body) to ensure that your personal data is treated by those third parties in a way that is consistent with and respects UK, EU and local data protection laws. Please contact us at dpo@marshmallow.co for more information on the protections that we put in place.
5. Presence of automated decision making
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We do not use Marshmallow Move Data to make any automated decisions.
6. How long we keep your personal data
We will only hold your personal data for as long as necessary to administer your policy, manage our business or in order to comply with legal or regulatory requirements. This will be in line with our data retention policy.
Please see our
main privacy notice for more information on how long we keep your personal data for.
7. Your rights under data protection legislation
Please see our
main privacy notice for more information on how to exercise your rights.
8. Where we store your data
We use cloud storage solutions within the UK and EU to store your personal data. In some situations, we may store your data in similar technologies outside of the UK or EU. In these cases, we will ensure that your personal data is stored in a way that is consistent with and which respects UK, EU and local laws on data protection.
9. Our contact details and how to make a complaint
If you have any concerns about this Privacy Notice or how we process your personal data, please email us at dpo@marshmallow.co and we will work with you to resolve the issue.
If you are still unhappy and would like to progress your complaint further, you have the right to make a complaint to the Information Commissioner’s Office (www.ico.org.uk).
10. Changes to this notice
We keep this Notice under regular review. Any material changes to this Notice will be sent to you by email.
Last updated: 11/12/2025