This Aviva MyDrive Privacy Policy (the “MyDrive Privacy Policy”) applies to users (“you”) who access and use the MyAviva app feature, Aviva MyDrive (“MyDrive”). It explains what Personal Information we collect about you when you use MyDrive and how we use it.
This MyDrive Privacy Policy is issued on behalf of the Aviva group companies within the United Kingdom. When we mention “Aviva", "we", "us" or "our", what we mean is the relevant company in the Aviva group that processes your Personal Information. For MyDrive, Aviva Insurance Limited, the company that underwrites your Aviva motor insurance policy, and Aviva UK Digital Limited, the company that is responsible for your use of the MyAviva app, are the main companies responsible for your Personal Information (each known as a controller). If you have any questions about this, please contact us using the details set out in section 6 (Contact Us) below.
Personal Information We Collect and How it is Used
The information on the Personal Information we collect and use below is in addition to the types of Personal Information and purposes relating to your Aviva motor insurance policy and use of the MyAviva app.
a. Sources of Personal Information
We obtain Personal Information from you when you activate and use MyDrive. We also obtain Personal Information from your MyAviva account and the device that you use to access MyDrive. As part of the MyDrive activation process, you’ll need to enable several in-app tracking permissions so MyDrive can record your journeys and monitor your driving behaviours.
These permissions may be phrased differently depending on the type of device you are using. Some devices call these permissions “Location Services” and “Motion and Fitness”, whereas other devices call these permissions “Location Services” and “Activity Recognition”. In some cases, you will also have to enable “Phone Activity” (so that we can detect distracted driving events) and switch off “Battery Optimisation” (so MyDrive can run in the background to detect journeys).
For MyDrive to work properly, these permissions must always be on. If you disable any of these permissions, we’ll notify you with in-app alerts. Whilst these permissions must be enabled at all times, we’ll only record information about your location, motion and phone activity when MyDrive believes you’re driving.
You’ll also be asked to enable push notifications so we can communicate with you and keep you up to date with your latest driving scores. However, unlike the in-app tracking permissions, push notifications are optional and are not essential for MyDrive to work properly.
Because MyDrive is a feature of the MyAviva app, switching off your MyDrive permissions will switch them off for the entire MyAviva app too. Therefore, if you turn off push notifications for MyDrive, you won’t receive any other MyAviva app push notifications. If you disable MyDrive, we will no longer be able to record your journeys or monitor your driving behaviours, even if your in-app tracking permissions are still enabled. However, if you wish to remove your in-app tracking permissions, you can do this in your device’s settings by clicking on the MyAviva app > Privacy.
Once you’ve selected your permissions, you’ll see an activation page to confirm MyDrive is activated.
Once you’ve activated MyDrive, there’s no need to log in to the MyAviva app every time you drive. So long as your in-app tracking permissions are enabled and your device is not in airplane mode or switched off, MyDrive will run in the background and automatically record your journeys and monitor your driving behaviours.
b. Types of Personal Information Collected and Created
The following data items will be captured in order for us to understand your driving behaviours and to build a profile of where, when and how you are driving your car.
MyDrive, using sensors in your device, will capture and record the following for each journey (“Driving Data”): · Time and date of journey; · Distance travelled (mileage data); · Acceleration & deceleration (accelerometer data); · Braking; · Cornering & lateral movements (gyroscope data); · Speed; · Direction of travel (magnetometer data); · GPS location/coordinates (latitude and longitude) and altitude; · Phone usage (also referred to as phone distraction or distracted driving)*; · Phone call status and audio pathway (used solely to determine whether you are on a call and if so, whether you are using a handsfree kit to speak or your device’s internal microphone and speaker. No details about the call (e.g., caller information or conversations) will be captured and recorded); · Road type (e.g., rural or urban); and · Journey routes, including location of journey start point and end point.
*Please note the following in respect to phone usage (also referred to as phone distraction or distracted driving):
- Phone usage means interacting with your device, such as touching the screen, making a call or answering a call. - Even if you use your device while your car is stationary or to make/receive a handsfree call, if MyDrive detects this, it may be recorded as distracted driving and contribute towards your driving score and rating. - If your device is used by a passenger while you are driving, this may be recorded in MyDrive as distracted driving and contribute towards your driving score and rating.
IMPORTANT: MyDrive automatically detects and records journeys by using multiple data points and minimum thresholds based on speed, time driving and distance travelled. It does not rely on you confirming that you are driving and when you have finished driving. So, please note the following when using MyDrive: · Once a journey has been detected (which may take a few minutes), MyDrive will always assume that you are the driver. If you are not the driver (for example, you are travelling as a passenger or are using public transport) you must let us know to make sure this journey doesn’t count towards your driving score. You can do this by clicking on the journey’s details in the MyDrive dashboard. Once you have let us know, this can’t be changed - the journey will be saved as a passenger journey and removed from the MyDrive dashboard. Once you start using MyDrive and updating journeys where you are the passenger, MyDrive will learn this behaviour and get to know you and your driving. It will get better at detecting when you are not driving and automatically save those as passenger journeys. This means they won’t be displayed in MyDrive and you won’t have to go in and change them yourself. · MyDrive will stop recording journeys when it no longer detects adequate motion. So, if you are in very slow-moving traffic or at a standstill, MyDrive may stop recording (because it thinks the journey has finished) and then restart the recording as a separate new journey when you start moving again. · At the end of each journey, it may take a few minutes for MyDrive to detect and validate there is no longer motion and in turn, confirm the journey has finished. In this period of time, and until validation has occurred, MyDrive may continue recording.
We will generate driving scores and ratings from your Driving Data. For every journey you make, you’re given a driving score out of 100 based on certain driving behaviours recorded by MyDrive.
Each journey will also receive a colour rating. Green means you’re driving well, amber means you’re driving well but there is room for improvement, and red means there is more room for improvement.
MyDrive will display an overall driving score and rating for each individual journey you make, and provide a breakdown score and rating for each of the following driving behaviours:
These driving behaviours are combined with speed limit data and information about how and when you use your car, like journey routes and times, to work out your overall driving score for each journey.
We will also create and share with you aggregated weekly, monthly and year-to-date driving scores and ratings which are based on the journeys taken in those time periods.
We will keep your Personal Information for as long as is reasonably required for the purposes set out in the “Uses of Personal Information” section below and our Aviva Motor Insurance Privacy Policy. For further information on our retention practices, please see our Aviva Motor Insurance Privacy Policy.
c. Uses of Personal Information
Your Personal Information may be used for a number of purposes, including the following:
· To monitor, record and analyse your driving behaviours and car usage in order to generate driving scores and ratings; · To communicate with you about your driving and driving scores; · To calculate a discount on your renewal price (if you satisfy the discount eligibility criteria). For further information, please see section 4 (Profiling and Automated Decision Making); · To validate and resolve queries associated with your journeys; · To ensure MyDrive works correctly, resolve any issues that arise and make further improvements; · To ensure you are using MyDrive in accordance with the MyDrive Terms of Use and the MyAviva app Terms of Use; and · To carry out data analysis to help us better understand MyDrive users’ driving behaviours and patterns. The results of this analysis may then be used for insurance risk modellin and product and pricing refinement. For further information, please see section 4 (Profiling and Automated Decision Making).
d. Lawful bases for uses of Personal Information
We are committed to collecting and using your Personal Information in accordance with applicable data protection laws. By law, we must have a legal justification, known as a lawful basis, in order to use your Personal Information for each of the purposes described in this MyDrive Privacy Policy. Our lawful bases are:
· Performance of a contract; and · Legitimate interests.
In connection with the purposes set out above, and in addition to the third parties set out in our Aviva Motor Insurance Privacy Policy, we may share your Personal Information with service providers who provide technology, systems, software, and other support services necessary to create and operate MyDrive and the MyAviva app.
Some of the organisations we share information with may be located outside of the UK. For further information on international data transfers, please see our Aviva Motor Insurance Privacy Policy.
Profiling and Automated Decision Making
We use profiling and other data analysis to build, train and audit our insurance models, algorithms and machine leaning tools. The models, algorithms and machine-learning tools we use help us do a number of things with your Personal Information. This includes the following: · To generate driving scores and ratings. These driving scores and ratings may then be used to provide you with feedback on your driving, develop and improve our pricing and risk models and if, you have met the discount eligibility criteria, help calculate a possible discount on your renewal price; · To detect fraudulent activity or misuse of MyDrive. For example, identifying any actions by you which could be a violation of the MyDrive Terms of Use or MyAviva app Terms of Use; · To ensure data quality and accuracy by identifying any inconsistencies or omissions when you use MyDrive; and · To detect whether you are the driver or passenger of a journey when you use MyDrive.
We may also make automated decisions based on your driving and the driving scores and ratings we generate as a result. This includes the following:
· Determining whether you are a driver or passenger of a journey when using MyDrive; and · At the point of renewal, if you have met the discount eligibility criteria, we may feed your driving scores and ratings into our overall rating algorithm to automatically calculate a possible discount on your renewal price.
Where we make an automated decision using Personal Information which has a legal or substantially similar effect, you have certain rights in relation to that decision. In particular, you have the right to receive meaningful information about the logic involved in relation to the decision, the right to human intervention and the right to obtain an explanation of the decision and challenge it.
For more information on profiling and automated decision making, including how to exercise your rights, please see our Aviva Motor Insurance Privacy Policy.
Data Rights
You have legal rights under data protection laws in relation to your Personal Information. For more information, please see our Aviva Motor Insurance Privacy Policy.
Contact Us
If you have any questions about this MyDrive Privacy Policy or how to exercise your rights, please contact our Data Protection Officer:
Write to: The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth PH2 1JR
If you'd like to submit a subject access request, please fill out this form here or write to us at the above address.
If you’re not happy with the way we’re handling your Personal Information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioner's Office (ICO). We ask that you please attempt to resolve any issues with us before contacting the ICO.
Updates
This MyDrive Privacy Policy is updated from time to time to take account of changes in our business activities, legal requirements and to make sure it’s as transparent as possible, so please check back here for the current version. You can see when this MyDrive Privacy Policy was last updated by checking the date below.
