Allianz Safe Driver App Fair Processing Notice
Allianz p.l.c. is committed to protecting your privacy.
Allianz p.l.c. is referred to in this document as “Allianz”, “we”, and “us” or “our”. Allianz is the Data Controller for Data Protection purposes, with the individual Allianz customer/ policy holder being the Data Subject.
This Fair Processing Notice is supplemental to the Fair Processing Notice provided to you in our Terms and Conditions and Policy documents. It gives you more detailed information about how we handle, manage and respect any personal information that we process in the context of our Allianz Family Car offer initiative (“Personal data”).
1. What personal data do we collect?
In the context of the Allianz Family Car offer initiative we collect the following data:
- Full Name
- Location/Tracking Data
- Email Address
2. How we collect your personal information
We collect the data directly from you, from the policyholder and from the Allianz Safe Driver app.
End user registers their personal data on the Allianz Safe Driver app and this will generate a user account linked to the specific email address provided.
What is the Safe Driver App?
The Safe Driver App is a free to download App which is intended to record, monitor, collect and track Data about Your driving behaviour. The information collected by the Safe Driver App about Your driving behaviour will be used to calculate Your Driving Score whilst Your Allianz insurance cover is in force. The information collected by the Safe Driver App includes Data, along with braking and acceleration patterns, speed, distance, GPS co-ordinates, route travelled and time of day.
The app monitors driving behaviour and scores based on four driving factors:
- Braking: frequent harsh braking increases the risk of an accident. Avoid harsh braking by driving with anticipation. Your braking style contributes 35% to your overall driving score.
- Acceleration: avoid harsh acceleration by driving with anticipation. Your acceleration style contributes 25% to your overall driving score.
- Speeding: Speeding is a common cause of accidents. Exceeding the speed limit leads to a negative rating. Respecting speed limits contributes 15% to your overall driving score.
- When and where you drive: Driving in heavy traffic or on rough roads often results in harsh braking. Day, time and type of road contribute 25% to your overall driving score.
The Allianz Telematics Platform (ATP) communicates with the app installed in end user's telephone receiving and processing the registered data.
Data- As mentioned, the data is collected from your Mobile Device by the Safe Driver App and is related to your driving behaviour. This includes, but is not limited to time, date, device model, Operating System version, battery level, GPS co-ordinates, gyroscope, distance travelled and accelerometer information.
Driving Score – A score ranging from 1-100 (one to one hundred) is calculated based on the analysis of your driving behaviour as recorded by the Safe Driver App using an algorithm. The overall Driving score is built up over time to provide a picture of your driving behaviour. Individual Identifiers that correlate data and drivers, including information on location, speed or driving events, may thus be personal data. This has implications for operators such as Allianz, as individuals have extended rights over their personal data.
3. Lawful Basis for Processing
The relevant Article 6 GDPR grounds for processing your personal data is as follows:
- for the performance of a contract and particularly to provide an insurance contract and insurance services to assist in the administration of a policy including any complaints or claims you may have. (including the calculation of your driving score and the monitoring of your adherence to the Terms & Conditions of the Allianz Family Car offer;
- for legitimate business interests for the purposes of investigating and resolving technical issues with the App;
- for the legal and regulatory obligations to which Allianz p.l.c. is subject to in the prevention and detection of fraud.
4. Third Parties
Your Data may be disclosed to third party service providers to provide support and resolution in the event of technical issues with the Safe Driver App.
Our Provider will have visibility of your data in order to carry out their technical operations. Details about the level of this visibility are outlined below.
The Allianz Telematics Platform (ATP) communicates with the app installed in the end user's telephone, receiving and processing the registered data. Personal data is collected through the app from the individual policy holder. ln particular, the Platform:
- Provides to the app an interface for both Try Before You Buy (TBYB) users and policy holders registration.
- Collects all location and sensor data transmitted by the app via Wi-Fi and / or mobile network (GSM/GPRS).
- Enriches location data with professional maps (e.g. to identify type of road or with public transport).
- Provides transit mode detection (e.g. car, bus, metro, train ).
- Provides trip processing (e.g. trip identification, harsh events identification).
- Provides score processing (e.g. near real-lime calculation of trip score, calculation of overall driver behaviour). The scoring algorithm is the one provided by AIISecur to Allianz Technology SpA.
- Stores trip details and scoring.
- Provides to the app an interface for trip details and scoring.
- Automatic email sending to guide users through the contract activation steps.
- Supported environments for development, integration and test in case end user has no longer an active profile, credentials are automatically locked in the Telematics Platform after a predefined amount of time set as a configuration parameters.
5. Retention Period
Allianz deletes your personal data above seven years after the contract ends as per internal Company rules and guidelines. Data for users on the Telematics Platform who do not register for the app is also retained for 7 years, after which it is deleted.
6. Data Security
Allianz uses a certified encryption method for data transfer that meets the highest standards. In addition the following measures are in place; Premise Access/Entry Control, System Access Control, Data Access Authorization Control, Transmission Control, Input Control, Job/Order Control, Availability Control, Data Separation Control. We regularly reassess our technical security measures to ensure security is consistently at the highest level for data security.
7. Data Accuracy/Up to date information
In order for us to keep your information accurate and up to date, please contact Allianz or your insurance intermediary (where applicable) if any of your details change. For contact details, please see “Contacting Us” below.
8. Protecting Information Outside the European Economic Area
As a general rule, we only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
However, your personal data may be transferred to and/or accessed from a country outside the European Economic Area (“EEA”), as a necessary aspect of performing the contractual service outlined. We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights.
Where we transfer your data to a non-Allianz Group member or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. Theses assurances are well recognised certification schemes like Standard Contractual Clauses (aforementioned alternative arrangement and safeguard). We will only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.
9. Automated decision making
Through the Allianz Safe Driver App, your driving behaviour is used to measure driving performance and to determine the nature and level of the risk associated with your insurance policy. In these cases, suitable safeguards are in place and you have the right to human intervention to express your interests and contest automated decisions. If you wish to review an automated decision with Allianz, please contact us on firstname.lastname@example.org.
10. Data Subject Rights
You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected. You also have the right to withdraw your consent for the processing of your personal data, have your personal data erased, or the processing restricted. Please note that withdrawing consent and requests for restriction/erasure may affect our ability to provide you with a contract of insurance. Some of the above rights are subject to limitations in order for us to comply with a number of legal and regulatory obligations. You have the right to data portability for insurance purposes (contact email@example.com). You also have the right to lodge a complaint with the Data Protection Commissioner. For further information, please see the section “Contacting Us” below.
11. Contacting Us
If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection Officer by either emailing, DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz p.l.c., Allianz House, Elm Park, Merrion Road, Dublin 4, D04 Y6Y6.
12. Supervisory Authority
You have the right to lodge a complaint with the Data Protection Commission (DPC), which is the complaints handling authority in Ireland. Information about how to contact the DPC can be found here- https://www.dataprotection.ie/en/contact/how-contact-us.