No insurance is provided as part of the Swiss Re Coloride Pilot. You acknowledge and agree that the data collected in the course of this pilot is provided in your capacity as a private individual and that Swiss Re will not provide any compensation for your participation in this Pilot. You remain responsible for obtaining and maintaining all appropriate and necessary licenses and insurance for your vehicle and all drivers. In addition you remain responsible for compliance with all laws and the terms of your employment contract with your employer, including applicable employer policies related to your vehicle and its use whether used in connection with your employment and/or your personal use. This shall include (but is not limited to):
This privacy statement is effective 1.10.2017.
This privacy statement relates only to the collection and use of personal data by Swiss Re Management Ltd. in Switzerland in relation to the Swiss Re Coloride Pilot (the "Pilot"). Swiss Re Management Ltd., Soodring 6, 8134 Adliswil, Switzerland ("Swiss Re") conducts the Pilot and is the data controller for any personal data collected and processed for the purpose of the Pilot.
This privacy statement applies each time you use the Swiss Re Coloride Pilot app.
For the purposes of this privacy statement, reference to personal data includes sensitive personal data as well.
Scope, Application and Purposes
This privacy statement explains how Swiss Re collects and uses personal data of participants in the Pilot obtained via the smartphone app on your mobile device (the "Swiss Re Coloride Pilot App"). The Pilot is conducted in order to provide our business partner (typically insurance companies, "Insurer") the means to test and assess Swiss Re Coloride Pilot App and related services, which Swiss Re may provide to Insurers. We understand that you, as Pilot participant ("Participant"), are typically an employee, agent or other business partners of Insurer and that you were invited by Insurer to participate in the Pilot at your own discretion.
The Swiss Re Coloride Pilot App collects personal data about Participants as explained in the section below. The purposes for processing personal data during the Pilot are: (i) to obtain data on motor vehicle drivers, driving behavior and data collected using other means of transportation (such as public transportation), analyze such data and improve our algorithms and scoring mechanisms; and ii) to allow an Insurer to test and evaluate the Swiss Re Coloride Pilot App and related services.
Please note that participation in the Pilot is entirely optional and at your discretion. Swiss Re shall collect and use personal data only to the extent required to carry out the Pilot. Swiss Re will not disclose personal data to any third party other than (i) as described in this Privacy Statement; (ii) to any regulatory authority, governmental authority or court except if we are required by law and ordered to do. A full set of de-identified data will be disclosed to the Insurer (i.e. your employer) for the purpose of evaluating the Swiss Re Coloride Pilot App. While Swiss Re ensures that the data is de-identified (i.e. the data is stripped from direct identifiers such as name, birthdate, etc.) we cannot rule out that Insurer will be able to identify you indirectly (e.g. based on GPS data).
Swiss Re Coloride Pilot App
a. What information does the Swiss Re Coloride Pilot App collect during the user registration process and how is it used?
Firstly, Swiss Re collects information on the Swiss Re Coloride Pilot App via a questionnaire during the registration process. This information can be divided into the following categories:
Participant details – this includes personal details such as first name, surname, age group, Swiss Re user ID, your email address, etc. This is to enable you to be a Participant in the Pilot and for us to be able to communicate with you in connection with the Pilot. We will also use this for analytics purposes, for example in analyzing data by region or age group. Additional information provided on a voluntary basis is a picture you may want to use for your profile, a pseudonym and gender.
Rating factors – this is information that you would typically expect to provide when applying for car insurance. For example, type of vehicle, brand, year of registration, accidents in past 5 years and previous driving fines (no criminal convictions). We use this information for analytics purposes, for example to determine a potential correlation between driving data and rating factors.
Driving behavior – this is information collected through social science questions designed to analyze your status and driving behavior. We use this information for analytics purposes, for example to compare driving behavior from drivers in the pilot against other comparable sets of data.
Please note that data collected through the user registration process may include sensitive personal data. By providing this data you are explicitly consenting to its usage for the purpose of the Pilot.
The questionnaire will show where questions are voluntary or mandatory in order to participate in the Pilot.
b. What additional information do the Swiss Re Coloride Pilot App and the dongle collect and how is it used?
The Swiss Re Coloride Pilot App collects the following information via your smartphone (in case you were given a dongle to be installed in your car, that dongle will collect the same data):
Your location (GPS coordinates), GPS accuracy and accelerometer data (speed and acceleration). This includes the precise real time location information (i.e. a time stamp) of the dongle and/or of the device on which the Swiss Re Coloride Pilot App is installed. This information is used in conjunction with the information collected via the Swiss Re Coloride Pilot App during the user registration process in order to analyze driving behavior.
c. What other information is used to determine driver rating?
In addition, other contextual information may be used to determine your driving score or rating. This includes environmental and contextual data such as road type, speed limit, location relating to bridges, tunnels, traffic flow and maps of the road network.
d. What information will I get back as part of the Pilot?
The Swiss Re Coloride Pilot App will give you information about your driving profile through some visual statistics about speed, acceleration, braking, cornering and jerking compared to the average of your colleagues in a common geographical area and to the average driver on your streets. By using the Swiss Re Coloride Pilot App, you are able to see the list of the trips that have been recorded by the app and some details for each trip (route, start time, end time, duration, distance and visual statistics about speed, acceleration, breaking, cornering and jerking).
e. What happens if I want to leave the Pilot?
You can leave the pilot at any time by sending an email to the following address: firstname.lastname@example.org. Your communication will trigger the removal of data that directly identifies you within one month of your request. However, please note that Swiss Re and its third party services providers connected to the Pilot will still hold de-identified information about your previously collected via the Swiss Re Coloride Pilot App and/or via a dongle (if any).
Collection of information can be stopped also by simply logging out from or uninstalling the Swiss Re Coloride Pilot App or deactivating the dongle. However, this will not trigger immediate deletion of data that directly identifies you. In any case, personal data that directly identifies you will be deleted within three months from the end of the pilot.
f. Cookies and other tracking technology
The Coloride Pilot App uses a token to permanently keep you logged in the application by default, unless you proactively log out from the application. By using the Swiss Re Coloride Pilot App you agree that we can use this token on your device.
g. Who holds my information and for how long for?
Swiss Re collects information via the Swiss Re Coloride Pilot App as explained above. Swiss Re also retains this data for an undetermined period. Personal data that directly identifies you will be removed no later than three months after the end of the Pilot.
During the course of the Pilot, Swiss Re will combine the driving data collected via the app with the data collected via the questionnaire during the user registration process for the purposes explained above. De-identified data set will be created for analytics purposes and identification data will be removed from the original data sets a maximum of three months from Pilot end.
Within Swiss Re and its affiliate movingdots GmbH, Bremen, only selected and traceable members of the Pilot team (data scientists and platform architects based in Switzerland and in the European Union) have access to your identifiable data collected during the user registration process and to the data collected via the app and they have been made aware of the confidential and sensitive nature of the data and how it should be handled. From time to time it may be necessary for Pilot team members from other Swiss Re offices to have access to the data on the same confidential basis.
The Insurer (i.e. your employer) will obtain a full set of de-identified data for the sole purpose of evaluating the Swiss Re Coloride Pilot App.
Please note that the de-identified data set will be used to improve Swiss Re's algorithms and scoring mechanisms and may be shared with the University of Milan/Italy and other research and business partners under non-disclosure agreements for their own analysis and scoring improvement purposes, but this will not contain directly identifiable information about the Participants.
h. What about data security?
We take adequate steps to maintain the security of personal data collected via the Swiss Re Coloride Pilot App and via the dongle.
i. Where will my information be processed?
In relation to the Pilot, all the data collected by the app will be stored with Swiss Re Management Ltd., Soodring 6, 8134 Adliswil, Switzerland and its cloud services provider, Microsoft, Richtistrasse 3, 8304 Wallisellen, Switzerland, which processes the information within its "West Europe" data center, located in The Netherlands.
We may also share personal data with our contracted service providers and advisors as well as research and business partners who may be located globally and so we may need to transfer your personal data to other countries. Before we do so, we take steps to ensure that your personal data will be given adequate data protection as required by relevant data protection laws and Swiss Re’s Group Data Protection Policy. In any case, personal data collected via the Swiss Re Coloride Pilot App during the user registration process and processed for the Pilot will only be processed by Swiss Re Management Ltd., Switzerland without involving third party services providers.
j. Can I access my data?
You will receive scores and journey information from the Swiss Re Coloride Pilot App as explained above via the app itself. You are also entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate or deleted. You can do this by contacting us through email@example.com.
The purposes for processing personal data during the Pilot are: (i) to obtain data on motor vehicle drivers, driving behavior and data collected using other means of transportation (such as public transportation), analyze such data and improve our algorithms and scoring mechanisms; and ii) to allow an Insurer to test and evaluate the Swiss Re Coloride Pilot App and related services.
Participation is at your sole discretion. You may terminate your participation at any time by sending an email to the following address: firstname.lastname@example.org
You agree to only activate and use the Swiss Re Coloride Pilot App if you are the driver of a vehicle or a passenger in other means of transportation, and you will not use the Swiss Re Coloride Pilot App for monitoring the driving behavior of other persons.