CONTENTS
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1. IMPORTANT INFORMATION AND WHO WE ARE
Sort My Car Limited (‘SMC’, and referred to as ‘we’, "’us’ or ‘our’ in this privacy policy)] is a private limited company registered under the laws of Scotland, with registration number SC780659 and with registered offices at 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN. SMC is the data the controller and responsible for your personal data.
Contact Details
· Email address: hello@sortmycar.co.uk
· Postal address: 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN
2. THE TYPES OF DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
· Identity Data, which includes first name, last name, any previous/maiden names, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data, which includes billing address, delivery address, email address and telephone numbers.
· Financial Data, which includes bank account and payment card details.
· Vehicle Data, which includes the registration make, model, ownership status, registration details, MOT and VED status of the vehicle you register for use of our services.
· Location Data, which includes precise and approximate location data for the vehicle you provide details of.
· Device Data, which includes information about the devices used to access our website, in
· Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us.
· Technical Data, which includes information about the devices used to access our website and services, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
· Profile Data, which includes your username and password, purchases or orders made by you, booking details, your interests, preferences, feedback and survey responses.
· Usage Data, which includes information about how you interact with and use our website, products and services.
· Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. HOW IS YOUR DATA COLLECTED?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· apply or register for our services;
· make a booking on our website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sourcesas set out below:
Technical Data is collected from the following parties:
· analytics providers such as Google based ourside the UK;
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside the UK.
4. HOW WE USE YOUR PERSONAL DATA
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
Purpose/Use |
Type of data |
Legal basis and retention period |
To register you as a new customer |
(a) Identity (b) Contact (c) Vehicle |
Performance of a contract with you Consent We will retain this data for 3 years |
To provide our Services, including: (a) To enable you to make a booking (b) To manage and confirm bookings
|
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for 3 years. |
To process and deliver our Services including: (a) Securely manage payments, fees and charges (b) Collect and recover money owed to us (c) Detect and prevent fraudulent transactions
|
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) [EXPAND ON THE ABOVE AND LINK LEGAL BASIS TO THE SPECIFIC PROCESSING ACTIVITY, USING EXAMPLES WHERE NECESSARY] [We will retain this data for [state retention period] |
To deliver our Services, including: (a) To schedule pick-ups and drop-offs (b) To collect and deliver your vehicle |
|
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your booking, requests, complaints and queries |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you We will retain this data for 3 years. |
To ensure the safety and security of the delivery process and prevent unauthorised access of our Services |
|
|
To manage loyalty programmes and referral schemes |
|
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation We will retain this data for 3 years. |
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) We will retain this data for 3 years |
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) We will retain this data for 3 years. |
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications We will retain this data for 3 years |
To carry out market research through your voluntary participation in surveys |
|
Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). We will retain this data for 3 years. |
We will not share your personal data with any third-party for their own direct marketing purposes without first obtaining your express consent.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data where necessary with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ in Section 4.
· Internal Third Parties, [including our drivers], as set out in the [LINK].
· [External Third Parties as set out in the [LINK].]
· [Specific third parties [listed in the table Purposes for which we will use your personal data above.]]
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside [the UK.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented: [We ensure your personal data is protected by requiring all our group companies to follow the same set of rules when processing your personal data. These rules are called "binding corporate rules" (BCR). To view our BCR, please contact us at hello@sortmycar.co.uk
[Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it as we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, Ireland and the USA.
7. DATA SECURITY
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We regularly review the personal data we hold and ensure that it is deleted, anonymised, or securely stored when it is no longer necessary. Our retention periods are designed to ensure that personal data is not kept for longer than necessary.
In some circumstances you can ask us to delete your data. For more information on this, please see Section 9 (‘Your legal rights’) or contact us directly.
9. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
· Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· 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.
· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of Marketing’ in Section 4 for details of how to object to receiving direct marketing communications).
· Request the transfer of your personal data to you or to a third party. 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.
· Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
· If you want us to establish the data's accuracy;
· Where our use of the data is unlawful but you do not want us to erase it;
· 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; or
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us at any of the following:
· Email address: hello@sortmycar.co.uk
No fee usually required
10. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. You can contact us at any of the following:
· Email address: [Details]
· [Postal address: [Details]]
· [Telephone number: [Details]].
11. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
12. THIRD-PARTY LINKS