1. About This Policy
We do not sell your data to third parties
Aftermath Ltd ("we", "us", "our") operates the Insuq platform, a digital service designed for driving instructors and learner drivers in Malta and the wider EU. This Privacy Policy explains in plain language what personal data we collect through the Insuq app and website, why we collect it, how we use it, and how we protect it.
We are committed to processing your data fairly, transparently and only for legitimate purposes. We do not sell, trade or otherwise transfer your personal information to third parties for their own commercial gain.
2. What Data We Collect & Why
We collect different types of data depending on how you use Insuq:
When you create an account: name, email address, phone number, date of birth, and optionally a profile photo
When you use study features: quiz answers, scores, module completion, flashcard results, and learning pace — used to personalise your experience and improve our content
When you book or conduct lessons: lesson dates, times, locations, instructor assignments, skill assessments and lesson notes
When you make payments: subscription tier and billing status — full payment card details are handled exclusively by our payment processor and never stored by us
When you use the app: device type, operating system, app version, pages viewed, features tapped, and session duration — used for bug fixing and platform improvements
When you contact support: the content of your messages and any files you share with us
All data collected is used to deliver, maintain and improve the Insuq service. We use aggregated, anonymised data for statistical analysis and product development — this data cannot identify you personally.
3. How We Use Your Data
To create and manage your account and provide access to the platform
To personalise your study journey based on your progress, quiz performance and weak areas
To enable instructors and students to communicate and coordinate lessons through the platform
To generate AI-powered lesson plans and skill recommendations based on progress data
To process subscription payments securely through our payment provider
To send service-related notifications such as lesson reminders, booking confirmations and account alerts
To send promotional content and product updates — only if you have explicitly consented
To improve our platform, fix bugs, and develop new features using anonymised usage analytics
To comply with our legal obligations under Maltese and EU law
4. Who We Share Your Data With
We share your data only as necessary and always under strict contractual data protection obligations. We share data with:
Cloud hosting providers — to store and serve the application (EU/EEA-based, GDPR-compliant)
Payment processors — to handle subscription billing securely (PCI-DSS certified)
Email and SMS service providers — to deliver notifications and marketing (only if consented)
Analytics providers — to understand usage patterns using anonymised, aggregated data only
Regulatory authorities — only where required by law or court order
We never sell, rent or trade your personal data with advertisers, data brokers or any other third party for commercial purposes. Your data is used solely to operate and improve Insuq.
5. Marketing & Promotional Emails
We love keeping you informed about new features, offers and driving tips — but only if you want us to.
We will only send you promotional emails, push notifications or SMS if you have explicitly opted in — during registration or via Settings → Notifications
You can opt out at any time using the unsubscribe link in any marketing email or via app notification settings
Opting out of marketing does not affect service-essential communications such as booking confirmations or account security alerts
We do not share your contact information with third parties for their marketing purposes
6. Your Privacy Controls
You are in control of your data. Within the Insuq app you can:
View and edit your profile information at any time (Settings → Profile)
Download a copy of your personal data (Settings → Privacy → Download My Data)
Delete your account and all associated data (Settings → Account → Delete Account)
Manage marketing and notification preferences (Settings → Notifications)
Manage cookie preferences (in-app cookie banner or Settings → Privacy)
For formal data subject access requests or to exercise any right under GDPR, contact our Data Protection Officer at dpo@insuq.com. We respond within 30 days.
7. How Long We Keep Your Data
We retain your data only as long as necessary:
Active account data is kept throughout your membership and for 3 years after account closure
Learning progress records are retained for 5 years to support appeals and references
Payment records are kept for 7 years to comply with Maltese tax law
Marketing consent records are kept for the duration of your membership plus 3 years
Anonymised and aggregated analytics data may be kept indefinitely for product improvement
When your data is no longer needed, it is securely deleted or permanently anonymised.
8. How We Protect Your Data
All data in transit is encrypted using TLS 1.3 (HTTPS)
Passwords are hashed using bcrypt — we cannot see your password
Access to personal data is restricted to authorised staff on a strict need-to-know basis
We conduct regular security reviews and vulnerability assessments
In the event of a data breach that poses a risk to your rights, we will notify you and the IDPC Malta within 72 hours as required by GDPR
9. Children's Privacy
The Insuq platform is intended for users aged 16 and above. Users under the age of 18 must have the consent of a parent or legal guardian prior to account creation. We do not knowingly collect personal data from children under 16.
If you believe a child under 16 has provided us with personal data without appropriate consent, please contact dpo@insuq.com and we will take prompt action to delete that data.
10. Policy Updates
We may update this Privacy Policy periodically. When we make significant changes, we will notify you via email and/or a prominent in-app notice at least 30 days before the change takes effect.
The current version of this Privacy Policy is always available within the app under Settings → Legal → Privacy Policy. The effective date at the top of this document indicates when it was last revised.
Contact & Queries
For any questions, data requests or complaints regarding this document, please contact our Data Protection Officer directly.
Company
Aftermath Ltd
Registered in Malta · EU VAT Registered
Data Protection Officer
dpo@insuq.com
Supervisory Authority
Office of the Information and Data Protection Commissioner (IDPC) — Malta
idpc.org.mt
© 2025 Aftermath Ltd — All rights reserved
Insuq® is a product of Aftermath Ltd, Malta