Website Privacy Notice in preparation for the  25th May 2018

 

In Laymans Terms

 

We respect the data of all our website users and Facebook advertising responders regardless of whether you are a client or not. We do not capture data for marketing purposes without your explicit consent, ie. you have to want to receive information from us and you need to ask for it. We do not share your data with other parties for any other reason than to provide a service which you must have asked for and the parties are limited to those who may be involved with the provision of a service such as a solicitor or legal advisor. Any data that is collected to maintain the performance of our website or advertising is anonymised.

 

 

1.   INTRODUCTION  
 
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.belt-up-drivingschool.co.uk including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 18 years of age.
 
Linda Jane Pasterfield trading as Belt-Up Driving School is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
 

Contact Details

Our full details are: Mrs Linda Jane Pasterfield

Full name of legal entity: Belt-up Driving School
 
Email address: Beltupdriving@aol.com

Postal address: 9 Burnham Beeches, Chandler's Ford, Hampshire, SO53 4QS

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
 
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at Beltupdriving@aol.com

 

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

If you are not a client and are simply visiting the website or have engaged with one of our Facebook adverts then the data we collect is submitted by you and is limited to contact details in general unless explicitly highlighted. Contact details are stored safely, not shared with parties outside of the company and its work force, and are used solely to contact you as requested by you.

We may process certain types of personal data about you as follows if you are a client:

 

1. Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.

2. Contact Data may include your billing address, delivery address, email address and telephone numbers. CURRENTLY we do not have client account areas on our website so none of this data is currently collected online on our website.

3. Financial Data may include your bank account and payment card details. CURRENTLY we do not have client account areas on our website so none of this data is currently collected online on our website.

4. Transaction Data may include details about payments between us and other details of purchases made by you. CURRENTLY we do not have client account areas on our website so none of this data is currently collected online on our website.

5. Technical Data may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

6. Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses. CURRENTLY we do not have client account areas on our website so none of this data is currently collected online on our website.

7. Usage Data may include information about how you use our website, products and services.

8. Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

 

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We need to collect the following sensitive data about you in order to deliver the services/products but it is unlikely we will collect this information via our website but more than likely by personal meeting and/or telephone. We may enquire via email if information required for the supply of the service is missing.

SENSITIVE DATA REQUIRED may include; marital status both present and past, intention to marry and the name of the intended, if you have been a resident of another country, if you are literate or illiterate, if you are expecting to inherit, if you have been an executor, if you have conducted probate,  estate valuation, the nature of the ownership of various assets such as property, the names and addresses of those you wish to include/exclude in/from your wishes, details of charities you may wish to/or currently support, your general mental health and lifestyle choice information.

 

DECISIONS CONCERNING THE SERVICES PROVIDED TO YOU WHICH MAY UTILISE SOME OR ALL OF ANY SENSITIVE INFORMATION COLLECTED FROM YOU ARE MADE BY HUMAN BEINGS NOT MACHINES.

We require your explicit consent for processing sensitive data, so when you submit your details, we will provide you a further communication asking for you to confirm your consent to this processing however the collection of this data is unlikely to be online.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

1. Direct interactions: You may provide data by filling in forms in person or on our site or by communicating with us by post, phone, email or otherwise, including when you:

2. order our services;

3. subscribe to our service or publications;

4. request resources or marketing be sent to you;

5. enter a promotion or survey, competition, prize draw; or

6. give us feedback.

7. Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies operated by third parties such as either Google or Facebook , server logs and similar technologies.

8. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

9. Technical Data from the following parties:

10. analytics providers such as Google based outside the EU;

 

1. advertising networks such as FACEBOOK based [inside OR outside] the EU and

1. Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [PAYPAL and BARCLAYS BANK PLC] based [inside OR outside] the EU].

2. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when legally permitted. The most common uses of your personal data are:

1. Where we need to perform the contract between us.

2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

3. Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at Beltupdriving@aol.com

 

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at privacy@assured-legal.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new customer

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Sensitive
(d) Financial
(e) Transaction
(f) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(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 to study how customers use our products/services

To enable you to partake in a prize draw, competition or complete a survey

(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

To administer and protect our business and our site (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

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

(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

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests to develop our products/services and grow our business

 

Marketing communications 

You will receive marketing communications from us if you have:

1. requested information from us or purchased goods or services from us; or

2. if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

3. in each case, you have not opted out of receiving that marketing. 

 

We do not share your personal data with any third party for marketing purposes with the exception of Mailchimp which is an email platform for the delivery of email, your name and email address are stored on our secure account with them.
 
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at Beltupdriving@aol.com

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at Beltupdriving@aol.com

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

1. Service providers who provide IT and system administration services.

2. Professional advisers including lawyers, auditors, bankers, and insurers who provide legal, consultancy, banking, insurance and accounting services.

3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

4. Third parties to whom we may sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  
We do not transfer your personal data outside the European Economic Area (EEA).

 

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  
 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
 
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

With your permission we may store your information and copies of documents created for you to enable amendments at a future time if you need to alter/change the/those document(s).

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

1. Request access to your personal data.

2. Request correction of your personal data.

3. Request erasure of your personal data.

4. Object to processing of your personal data.

5. Request restriction of processing your personal data.

6. Request transfer of your personal data.

7. Right to withdraw consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at Beltupdriving@aol.com
 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternativelly, we may refuse to comply with your request in these circumstances.
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 10. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. The cookies which may be associated with this site are operated by third parties such as either Google or Facebook.

12. FACEBOOK ADVERT RESPONDERS

We use advertising on Facebook to promote our services and in addition to the above we make it clear that the detail you supply via the advert form is;

1. Not shared with any entity outside the company except where required so by law

2. Used solely to contact you in response to your reply, in the first instance by text and/or   phone, and sometimes but not always by email

3. If we fail to contact you on receipt of your response to the advert after one (1) calendar month we may text/email you to seek permission to either continue our efforts to contact you or to close your enquiry. We will only do this if the advert was offering a free service as an attempt to ensure you do not miss out unintentionally

4. The data collected relating to uncontacted enquiries will be deleted after 6 months

5. The personal data collected, passed to us via the Facebook Advert and then used by us is limited to NAME, POSTCODE, TELEPHONE NUMBER AND EMAIL ADDRESS and again we do not share or sell this data.

6. If you responded to our Facebook advert before the 25th May 2018 you will receive an email to seek permission to continue to contact you regarding related matters to your original enquiry or to delete you from our data base.