1 Introduction
1.1 Who we are
Welcome to Rivr Cover Limited’s Privacy and Data Protection Policy (“Privacy Policy”).
At Rivr Cover Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Your Data Controller
Rivr Cover Limited is your Data Controller and responsible for your Personal Data. Therefore, any inquiries about your data should either be sent to us by email to [email protected] or by post to 4 Galton Street, London, W10 4QN, United Kingdom.
We are registered with the UK’s Information Commissioner’s Office (ICO) under number ZB578659.
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 Data we may collect about you
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Personal and contact data: This is data that you provide when you purchase an insurance policy or interact with our support team and includes your name, date of birth, email address and phone number.
Insurance policy details: When you purchase a policy or obtain a quote from us we will keep a record of the policy, and will collect information about the insurance risk necessary to provide a quote. We will also collect information concerning any individual voluntary arrangements, county court judgements or bankruptcies.
Website usage: such as details of visits to our websites and information collected through cookies and other tracking technologies including your domain name, browser version, operating systems, traffic data, location data, web logs and other communication data.
Financial data: These are your banking details such as your account number and sort code. These are passed to our premium finance partner. We do not store any other financial details such as credit or debit card details. These are securely handled directly and independently by our payment providers who only provide a payment confirmation to us.
1.4 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
2. How we use your personal data
2.1 Our data uses
We will only use your Personal Data when the law allows us to.
Set out below is a list containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 1.4 for more information on the lawful basis listed in the table below.
Examples provided below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
The type of things we use your data for are:
To provide our services effectively: Like selling you insurance, helping us manage your account or improving our services. Our legal ground for doing this is ‘legitimate interests’ as it enables us to perform our obligations and provide our services to you.
To carry out necessary compliance and fraud checks: Our legal grounds for doing this is our ‘legitimate interests’ to ensure that you fall within our acceptable risk profile and to assist with the prevention of fraud.
To inform you of changes to our services: Our legal basis for this is our ‘legitimate interests’ to conduct our business.
2.2 Marketing and content updates
You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
2.3 Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
3 Your rights and how you are protected by us
3.1 Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 3.5 below for more details on how you can make a data subject access request.
Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
(i) Where we are processing your personal data for direct marketing purposes.
(ii) Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
(iii) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
(i) If you want us to establish the data's accuracy.
(ii) Where our use of the data is unlawful but you do not want us to erase it.
(iii) Where 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.
(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to make a request under any of these rights, please contact us at [email protected].
3.2 Your control over Rivr Cover Limited’s use of your Personal Data
We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a passcode for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your passcode appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
3.3 How Rivr Cover Limited protects customers' Personal Data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your
Personal Data on our systems, including We implement certain security measures to ensure the security of your Personal Data on our systems by adopting a secure protocol and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Rivr Cover Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
3.4 Opting out of marketing promotions
You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing messages at any time by unsubscribing from any marketing communications.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
3.4 How to request your data and the process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4 Your data and third parties
4.1 Sharing your data with third parties
We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions. The third parties that we may pass your personal data to fall into the following categories:
Data controllers (who process your personal data independently and under their own policies):
Intercom: Any data you share using our customer support service is accessible by Intercom as described in their Terms of Service.
Mailchimp: We may provide personal data for the purpose of sending marketing emails.
Insurance and claims handling: We may provide companies in the Bspoke Group and HDI Group with your personal data for the purposes of underwriting the insurance provided and to support the handling of claims. More information about their handling of your personal data can be found here. In order to process your claim, we will also share your information with our claims handlers.
Premium finance providers: We may pass your data to companies that provide premium financing.
Compliance: We may also pass your data to companies that perform fraud and crime checks. We are required by law to do this.
Partners: We may share your data with anyone who you give us explicit permission to share with. You’ll always agree to this before we share anything.
Data processors (who process your personal data on our behalf and under our instruction and subject to our privacy safeguards):
Technology providers: We use various cloud and technology providers to offer our service (for example, hosting providers), they will only have access to your data with our consent. Usually, they only have access to anonymised or aggregated data.
We may also share Personal Data with interested parties in the event that Rivr Cover Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If Rivr Cover Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
4.2 Third-party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.
4.3 Other people’s consent
If you choose to share someone's information with us, it's your responsibility to ensure they consent or someone with parental responsibility for them consents.
5 How long we retain your data
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
6 International transfer of data
We store all your data within the European Economic Area (“EEA”), but it may be processed or viewed by staff or companies outside the EEA who work for us or one of our partners. Regardless of location, we’ll always impose on our employees or contractors the same data protection safeguards that we use inside the EEA. Where we are transferring your data to countries which are outside the EEA and that have not been approved by the European Commission as providing essentially equivalent protections to within the EEA, we will transfer it subject to European Commission approved contractual terms.
7 Notification of changes and acceptance of policy
We keep our Privacy Policy under review and will place any updates here. This version is dated 4 January 2024.
By using Rivr Cover Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Rivr Cover Limited will constitute your express acceptance of any modifications to this Privacy Policy.
8 Interpretation
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorised to contract on behalf of Rivr Cover Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Rivr Cover Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Rivr Cover Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Rivr Cover Limited legal department.