It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (“UK GDPR”).
We are the controller of personal data obtained via the Website and our services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.
Personal identification information
The personal data we collect about you depends on the particular activities carried out through the Services. We may collect personal data from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, fill out a form, subscribe to the newsletter and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, full name, company/organisation name, company number, email address, mailing address, phone number, description of message, vehicle details including registration number, make and model.
Below is a detailed description of the type of personal data we collect and its purpose.
|Category of data
|In more detail
|Identify and account data you input into the Services
Registration is required in order to use the Services
|Your first and last name Your business/company name Your email address Your mobile or telephone number Your postal address Your payment history Your gender Your date of birth The last 4 digits of your debit/credit card Mode of payment (e.g. MasterCard, Visa, Apple Pay, GooglePay)
|Data collected when you use specific functions in the Services
|Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
|Other data the Services collects automatically when you use it
|Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use unique device identification, browser version, time zone settings, location, operating system, OS version
|Data collected when you make an enquiry with us
|Your first and last name Your email address Your message
Users may, however, visit our Site anonymously.
We will collect personal data from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal data, except that it may prevent them from engaging in certain Site related activities.
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How and why we use collected data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.
The table below explains what we use your personal data for and why.
|What we use your personal data for
|Create and manage your account with us
|To perform our contract with you or to take steps at your request before entering into a contract
|Providing the Services to you and processing orders
|To enforce legal rights or defend or undertake legal proceedings
|Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
|Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or other important notices, update about your order
|Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
|Protect the security of systems and data
|To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
|Operational reasons, such as improving efficiency, training, quality control or to provide support to you and improve customer service
|For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
|Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, Website and functionalities and offerings or other efficiency measures
|For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our Website
|Updating and enhancing user records, to more effectively respond to your customer service requests and support needs
|To comply with our legal and regulatory obligations
|To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary
|Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets
We intend to send you email marketing or SMS/messages to inform you of our Services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
- contacting us at firstname.lastname@example.org or 01179428678
- using the ‘unsubscribe’ link included in all marketing emails or messages you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- our employees and sub-contractors who will be bound by confidentiality obligations
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Transferring your personal data outside of the UK
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
How long your personal data will be kept
We will keep your personal data for as long as you have an active account/agreement with us and for a period of up to 6 months thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims.
Once your engagement with us is terminated, we will retain your personal data in our core application database and backups (if any) for 6 months after termination.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
|Access to a copy of your personal data
|The right to be provided with a copy of your personal data.
|Correction (also known as rectification)
|The right to require us to correct any mistakes in your personal data.
|Erasure (also known as the right to be forgotten)
|The right to require us to delete your personal data—in certain situations.
|Restriction of use
|The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
|The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
|To object to use
|The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
|Not to be subject to decisions without human involvement
|The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘Contacting us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website or email, call or write to us—see below: ‘Contacting us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Origin Workspace 40 Berkeley Square Bristol BS8 1HP