Privacy Policy

Julu 6th 2021

Who are we?

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

Our Commitment

We are committed to protecting and respecting your privacy. If you have any questions about your personal information please chat with us through marshmallow.com, or by emailing us at help@marshmallow.com, or by writing to us at Marshmallow Financial Services, Fourth Floor, 80 Old Street, London, EC1V 9AZ.

What information we hold about you


- Information that you submit through www.marshmallow.com or partnered comparison sites when we are arranging and administrating insurance policies.

For example when you provide information to us such as your name, address, and registration plate.

There may be times where you give us sensitive information such as your biometric data. We will only use this in strict accordance with the law.

- Information that your browser sends us when you visit our site.

This may include your IP address, browser type, browser version, pages that you visit on our site, the time you spent on those pages and other statistics.

- Information from any social network or online account that you share with us.

How we use your information

To provide our service we use it to:

- Make responsible financial decisions, like offering you an insurance product.

- Track, analyse and improve the services we provide you and other customers.


- Search your record at credit reference agencies (this is a ‘soft search’ and shouldn’t impact your credit score).

- Search your record at No Claims Bonus databases and Claims databases.

- Search your record at fraud prevention agencies.

To meet our legal obligations. We use it to:

- Prevent illegal activities such as fraud and money laundering

With your consent. We use it to:

- Market third party products and services (see table below) where we think these services may be of interest to you by your preferred method/s: telephone, SMS, post or by Email. You can always unsubscribe from receiving these communications after opting in by clicking 'unsubscribe' at the bottom of the communication. 

Who will we share your data with?

We may share your personal information with:

- Analytical, Know Your Customer (KYC) and cyber security providers.

- Fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If Fraud is detected, you could be refused certain services, finance, or employment (for more information on how they use data please read the Fraud Prevention Agency Fair Processing Notice).

- Third parties that carry out advertising services for us (but we won't share identifiable personal data with these third parties for their own marketing purposes unless you give us permission, and you can opt out)

- Credit reference agencies (for information on how they use data please read the Credit Reference Agency Information Notice)

- Customer 'interface' providers (like the ones who manage our sites chat service)

- Anyone who you give us explicit permission to share it with

We'll also share it to comply with the law; to enforce our Terms and Conditions; or to protect the rights, property or safety of us, our customers or others.

Data we share to provide a quote

Company details
Categories of data shared
Purpose for sharing
Lawful basis

Claims and Underwriting Exchange (CUE), Motor Insurers’ Bureau of Linford Wood House, 6-12 Capital Drive, Milton Keynes MK14 6XT
Website
0345 1652803
dataprotection@mib.org.uk

Name
Date Of Birth
Address
Vehicle Registration Number

Confirmation of declared and known previous claims and NCD

Legitimate interests

Segment.io, IncSegment.io, Inc. 100 California Street, Suite 700 San Francisco, CA 94111 USA Attention: Data Protection Officer
Website

Address
Date Of Birth
Email Address
Name
Phone Number
Postal Code
Vehicle Registration Date
Policy Number
Exit Survey
Quote Start Date
Quote End Date
Quote Price
First Test Pass Country
NCD Status
Access To Other Cars
Vehicle PurchaseDate
UK Licence Status
Licence Length
Title
Years NCD
Have Any Claims In Last 5 Years (Yes/No)
Have Any Convictions In Last 5 Years (Yes/No)
Occupation
Industry
Estimated Annual Mileage
Vehicle Make
Vehicle Model
Selected Add Ons
Marketing Opt In
Exit Survey Answers
IP Address

Customer Relationship Management

Enabling quotes to be saved and resumed within a given time period

Capturing your marketing preferences

Legitimate interests

Amplitude, Inc
Attn: Privacy631 Howard Street, Floor 5San Francisco, CA 94105
Website

Same as for Segment

Only applicable if you use our website to get a quote directly)

Legitimate interests

Vero Holdings Australia Pty. Ltd
+61 (2) 8505 8607
or
+1 (650) 643 9866.
Vero Holdings Australia Pty Ltd.
Level 1, 251 Riley Street
Surry Hills
NSW, 2010
Australia
Website

Same as for Segment

Only applicable if you use our website to get a quote directly). Providing you with the ability to resume a saved quote via your email link.

Legitimate interests

Cheshire Datasystems Ltd,
Data Protection Officer, CDL, Strata House, Kings Reach Road, Stockport, SK4 2HD

dataprotection@cdl.co.uk

Vehicle Registration Number

Only applicable if using our registration plate search feature. Used to find vehicle details for your provided vehicle registration number.

Legitimate interests

LoqateGB Group PLC
GB Group Plc
The Foundation
Herons Way
Chester Business Park
Chester
United Kingdom
CH4 9GB

Company Registration Number: 02415211

compliance@gbgplc.com or 01244 657277.

UK Address
Address in previous country where applicable

Only applicable if you use our address lookup feature. Used to assist you in finding and correctly entering your address

Legitimate interests

Trans Union LLC
One Park Lane,
Leeds,
West Yorkshire, LS3 1EP.

TransUnion International UK Limited

1-866-310-8783

Name
Email
Address
Date Of Birth

Credit checking, detection of suspected or reported fraud linked to your details

Performance of a Contract

Emailage Limited,
16 Great Queen Street,
Covent Garden,
London
WC2B 5AH

Privacy@emailage.com

Email
Phone Number
Name
IP Address
Address

Fraud and identity theft detection linked to your details.

Legitimate interests

FullStory,
FullStory, Inc.

privacy@fullstory.com

FullStory
Attn: Privacy
1745 Peachtree St
NESuite G
Atlanta, GA 30309

Website

Policy Number
IP Address

Behavioural analytics and product development

Legitimate interests

Ravelin Technology Limited
5th floor,
174-180 Old Street,
London
EC1V 9BP

privacy@ravelin.com

IP Address
Vehicle Registration Plate
Phone
Email
Postal Code

Fraud prevention

Legitimate interests

Bugsnag Inc., a Delaware corporation (“Bugsnag”)

Level 5, The Old Malthouse, Clarence Street, Bath, United Kingdom, BA1 5NS

privacy@bugsnag.com

IP Address

Software crash analytics

Legitimate interests

Amazon Web Services
EMEA SARL,
38 Avenue John F. Kennedy,
L-1855, Luxembourg

ATTN: AWS EMEA Legal

All categories of data

Storage of information and processing of data.

Performance of a Contract

Percayso

25 Regent St, Nottingham,NG1 5BS,United Kingdom

Registration plate
Car make
Car model
Car build year

For all drivers (where available):
Title
First name
Last name
Date of Birth
Licence number
Licence country
Occupation
Current Address
Claim year
Claim month

Fraud prevention
General information check
Data collection for underwriting logic

Legitimate interest

Data we share to issue a policy

Company details
Categories of data shared
Purpose for sharing
Lawful basis

Stripe Payments Europe, Ltd.
1 Grand Canal Street Lower, Grand Canal Dock, Dublin.

privacy@stripe.com

dpo@stripe.com

Card Number
Email
Card Expiry
Card CVC
Vehicle Registration Number
Billing Address Post Code
Name
Policy Number
Charge Amount
IP Address

Payment for the policy or policy deposit in the case you opt to pay monthly

Performance of a Contract

Trans Union LLC
One Park Lane,
Leeds,
West Yorkshire,
LS3 1EP.

TransUnion International UK Limited

1-866-310-8783

Name
Address
Bank account number
Bank sort code

Bank details verification, applicable only if you decide to pay monthly

Performance of a Contract

PremFina Limited (only if you opt to pay by monthly instalments)

PremFina Limited
Attn: Compliance
Lansdowne House,
1st Floor
57 Berkeley Square
Mayfair
London
W1J 6ER

info@premfina.com

+44 203 500 3462

Policy Number
Title
Name
Address
Date Of Birth
Email Address
Start Date
Bank Account Name
Bank Account Number Sort Code
Phone Number
Policy Price Details

Collection of monthly payment direct debit if you decide to pay monthly.

Performance of a Contract

Mulsanne Insurance Company Limited First Floor, GrandOcean Plaza, Ocean Village, Gibraltar.

Policy Number
Policy Start Dat
Policy Start Time
Policy End Date
Policy End Time
Policy Cost
Monthly Or Annual Payment
Vehicle Registration Plate
Vehicle First Registration Date
Vehicle Purchase Date
Vehicle Steering Type
Declared Vehicle Modifications
Vehicle Seat Count
Vehicle Security Model
Vehicle Security Fitted
Use Class,
Vehicle Value,
Overnight Storage,
Overnight Postcode,
Annual Mileage
Ncb Proven
Ncb Status
Ncb Years
Ncb Entitlement
Ncb Protected
Compulsory Excess
Voluntary Excess
Total Excess
Title,
Name
Age
Marital Status
Birth Date
Address
Postal Code
Phone Number
Email Address
Other vehicles Owned,
Other vehicles with Access,
Time In UK,
Use Of Other Cars,
Insurance Previously Refused
Licence Type
Licence Date
Occupation
Occupation Industry Policy Holder Claims
Policy Holder Convictions
Additional Drivers
Additional Driver Claims
Additional Driver Convictions

Provisioning of the insurance policy

Performance of a Contract

Key Claims and Administration Services Limited
Registered Address: 15-17 Mount Ephraim Road, Tunbridge Wells, Kent, TN1 1EN

ICO number no: ZA176535
  
Services: Administration 

DataProtection@key.claims

01273741900

Same as for Mulsanne

Provisioning of the insurance policy for claims management

Performance of a Contract

Intercom
55 2nd Street, 4th Fl., San Francisco, CA 94105,

USAcompliance@intercom.com

Same as for Segment

Customer relationship management to provide support for your policy

Legitimate interests

The Rocket Science Group LLC
(Mandrill & Mailchimp)

The Rocket Science Group LLC d/b/a Mailchimp
Attn. Privacy Officerprivacy@mailchimp.com
675 Ponce de Leon Ave NE,
Suite 5000
Atlanta,
GA 30308 USA

dpo@mailchimp.com

Email Address

Sending of emails, such as your policy documents, renewal notifications and changes to your policy

Performance of a Contract

AXA Insurance UK Plc
Brooke Lawrance House
80 Civic DriveIpswich
Suffolk IP1 2AN

dataprotection.ins@axa-insurance.co.uk


Policy Number
Title
Name
Date Of Birth
Phone Number
Email Address
Address
Post code
Vehicle Registration Number
Vehicle Registration
YearVehicle Type
Vehicle Make
Vehicle Model
Vehicle Colour
FuelType

Only relevant if you buy breakdown cover. Data is shared for the provisioning of your additional protection.

Performance of a Contract

Lawshield UK Ltd
Lawshield House,
850 Ibis Court,
Warrington,
Cheshire,
WA1 1RL

dataprotection@lawshield.co.uk

0800 731 3942

Policy Number
Name
Title
Company
Address
Postcode,
Vehicle Make
Vehicle Model
Vehicle Registration Number
Date Of Birth

Only relevant if you buy legal expenses protection. Data is shared for the provisioning of your additional protection.

Performance of a Contract

Onfido
Attention: Privacy Onfido Limited
3 Finsbury Avenue
London
EC2M 2PA
United Kingdom

privacyrequests@onfido.com

Name
Address
Date of birth
Email address

Identity verification

Performance of a Contract

LexisNexis Risk Solutions

Lexis House,
30 Farringdon Street
London
EC4A 4HH,
United Kingdom

LexusNexus

Policy Number
Title
Name
Date of Birth
Current Address
Vehicle Registration Number
Vehicle model year
Vehicle make
NCD years
NCD Protection

NCD verification

Legitimate interests

Checkout Ltd
Data Protection Officer,
Checkout Ltd,
54 Portland Place,
London,
W1B 1DY 
United Kingdom

dpo@checkout.com

Checkout Ltd is registered with the UK Information Commissioner’s Office (ICO) under number ZA071209

Card Number
Card Expiry
Card CVC
Vehicle Registration Number
Billing Address
Name
Email
Policy Number
Charge Amount
IP Address

Payment for the policy or policy deposit in the case you opt to pay monthly

Performance of a Contract

PLAID FINANCIAL LTD (“Plaid”) 

Plaid Financial Ltd.

Attn: Legal
New Penderel House,
4th Floor
283-288 High Holborn
London,
United Kingdom,
WC1V 7HP

privacy@plaid.com

ICO number: ZA526676

We do not share any categories of data collected by us with Plaid.

Plaid gains consent in its own right as a joint controller to collect data about your bank account on our behalf and share that data with us.

This information includes: 
- Transaction data
- Identity data, such as: address, email, name and phone number
- Balance and account type.

Payment for the policy or policy deposit in the case you opt to pay monthly

Performance of a Contract

Compare The Market

Data Protection Officer at Compare the Market Limited,
Pegasus House,
Bakewell Road,
Orton Southgate,
Peterborough,
PE2 6YS.

BGL Group LimitedICO Number: Z6137356

ctm.dpo@bglgroup.co.uk

Policy Number
Name
Email
Date Of Birth
Postcode
Vehicle Registration Number

Confirmation of sale.
This partner is only applicable if you got your quote and purchased your policy via Compare The Market.

Performance of a Contract

Gocompare.com Limited

Gocompare.com Limited
Imperial House
Imperial Way
Newport
NP10 8UH

ICO number:
Z9662879

Tel: 01633 654060
dpo@gocompare.com


Name
Date Of Birth
Postcode
Policy Number
Vehicle Registration Number
Email

Confirmation of sale.

This partner is only applicable if you got your quote and purchased your policy via Go Compare

Performance of a Contract

Quotezone

Seopa Limited
5th Floor Link Building,
Adelaide Exchange,
24-26 Adelaide Street,
Belfast, BT2 8GD

ICO Number: Z8733752
info@quotezone.co.uk

Name
Date Of Birth
Postcode
Policy Number
Vehicle Registration Number
Email

Confirmation of sale.

This partner is only applicable if you got your quote and purchased your policy via Quotezone or its affiliates.

Performance of a Contract

ComplyAdvantage

IVXS UK Limited,
4th Floor,
90 Long Acre,
London
WC2E 9RA 

Registered with the UK Information Commissioner’s Office under number ZA054290.
 
dpo@complyadvantage.com

Name
Policy Number
Year of Birth

Sanctions list checking

Performance of a Contract

WNS ASSISTANCE LIMITED
 
Acre House 11-15 William Road London NW1 3ER
ICO Number ZA188624

privacy@wns.com

Policy Number
Policy Start Date
Policy Start Time
Policy End Date
Policy End Time
Policy Cost
Monthly Or Annual Payment
Vehicle Registration Plate
Vehicle First Registration Date
Vehicle Purchase Date
Vehicle Steering Type
Declared Vehicle Modifications
Vehicle Seat Count
Vehicle Security Model
Vehicle Security Fitted
Use Class
Vehicle Value
Overnight Storage
Overnight Postcode
Annual Mileage
Ncb Proven
Ncb Status
Ncb Years
Ncb Entitlement
Ncb Protected
Compulsory Excess
Voluntary Excess
Total Excess
Title
Name
Age
Marital Status
Birth Date
Address
Postal Code
Phone Number
Email Address
Other vehicles Owned
Other vehicles with Access
Time In UK
Use Of Other Cars
Insurance Previously Refused
Licence Type
Licence Date
Occupation
Occupation Industry 
Policy Holder Claims
Policy Holder Convictions
Additional Drivers
Additional Driver Claims
Additional Driver Convictions

Provisioning of the insurance policy for claims management

Performance of a Contract

Marshmallow Insurance Limited

Suite 23,
Portland House,
Glacis Road,
Gibraltar

dataprotection
@marshmallowinsurance.com

Policy Number
Policy Start Date
Policy Start Time
Policy End Date
Policy End Time
Policy Cost
Monthly Or Annual Payment
Vehicle Registration Plate
Vehicle First Registration Date
Vehicle Purchase Date
Vehicle Steering Type
Declared Vehicle Modifications
Vehicle Seat Count
Vehicle Security Model
Vehicle Security Fitted
Use Class
Vehicle Value
Overnight Storage
Overnight Postcode
Annual Mileage
Ncb Proven
Ncb Status
Ncb Years
Ncb Entitlement
Ncb Protected
Compulsory Excess
Voluntary Excess
Total Excess
Title
Name
Age
Marital Status
Birth Date
Address
Postal Code
Phone Number
Email Address
Other vehicles Owned
Other vehicles with Access
Time In UK
Use Of Other Cars
Insurance Previously Refused
Licence Type
Licence Date
Occupation
Occupation Industry 
Policy Holder Claims
Policy Holder Convictions
Additional Drivers
Additional Driver Claims
Additional Driver Convictions

Provisioning of the insurance policy

Performance of a Contract

National Windscreens Limited

Silica House,
Galena Close,
Tamworth,
Staffordshire
B77 4AS

informationsecurityofficer
@nationalwindscreens.co.uk

Name
Address
DOB
Vehicle Registration Number
Policy number

Provisioning of the insurance policy for claims management.

Performance of a Contract

Presence Of Automated Decision Making

We utilise automated decision making technology about whether you are eligible for a quote or policy. This process uses information provided by you in combination with additional data, sourced from our partners, listed above, to automatically classify risk levels which may impact whether we decide to offer you a quote or policy.

As per GDPR Article 15.1.H, the table below contains information about the logic involved and envisaged consequences:

Process
Logic
Possible consequences

Credit Checks

Confirmation and detection of your declared CCJ and bankruptcy status with credit score

You may not be offered a quote, previous quotes may become invalidated.

Claims & Underwriting Exchange

Confirmation of declared and other known previous claims

You may not be offered a quote, previous quotes may become invalidated

Fraud Database Checks

Detection of suspected or reported fraud linked to your details

You may not be offered a quote, previous quotes may become invalidated.

Misrepresentation & suspicious behaviour detection

Detection of suspicious behaviour or misrepresentation of your details

You may not be offered a quote, previous quotes may become invalidated.

Identity Verification

Authenticity of ID documents and pictures submitted when you buy a policy

You may not be offered a quote, previous quotes may become invalidated.

Bank Details Verification

Authenticity of Bank details

You may not be offered a quote, previous quotes may become invalidated.

Open Banking Checks

Affordability checks, fraud risk assessment and identity verification

You may not be offered a quote, previous quotes may become invalidated.

How long will we keep your information

We will only hold your information for as long as necessary to administer the policy, manage our business or in order to comply with legal or regulatory requirements. This will be in line with our data retention policy.

Your Rights

You have a right to:

- Access the personal data we hold about you, or to get a copy of it.

- Make us correct inaccurate data.

- Ask us to delete, 'block' or suppress your data, though for legal reasons we might not always be able to do it.

- Object to us using your data for direct marketing and in certain circumstances ‘legitimate interests’, research and statistical reasons.

- Withdraw any consent you’ve previously given us.

To do so, please contact us by emailing help@marshmallow.com.

What we will not do

- We won’t share identifiable personal data with third parties for their direct marketing unless you give us permission.
- We will only keep your personal information for only as long as we need to. We’ll then delete it securely and safely.

Where we store your data

The data we collect from you is stored encrypted inside of the European Economic Area (“EEA”).

When we store your data we:
Use industry standard means of securing your personal information.
Encrypt your information when we send it over the internet.
We try to seek partners that also encrypt your information.

Cookie policy

Like most websites, we use cookies on the Marshmallow websites. Cookies are small text files used to store information on web browsers. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this policy, we refer to all of these technologies as “cookies.”

Cookies help to improve the Marshmallow website and give you a better experience. For example, they can help recognise you if you visit the Marshmallow website often and we can use them to understand how you use our website and understand how effective it is, including any advertising we show you. We use cookies to help us show ads to you about products, services and causes which we be think you would be interested in. For example, if you were exploring the Marshmallow website and looking at information about how we support foreign drivers with international licences, we could use cookies to show you advertisements about international licences rather than things that you may not be interested in.

If you wish to block cookies you can do this in your browser settings; the Help function within your browser should tell you how. Alternatively, just search ‘how to block cookies’.

How to make a complaint

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.

Changes to this policy

Any material changes we make to our privacy notice in the future will be posted on this page and, if appropriate, sent to you by email.