How we use your data
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.
This privacy notice applies to personal information processed by or on behalf of 1st Gear Driver Training.
The following points refer to the policy below which will let you find out more about how we use your personal information:
· Who are we and how do you contact us and our Data Protection Officer?
· What kinds of personal information about you do we process?
· What is the source of your personal information?
· What are the legal grounds for our processing of your personal information (including when we share it with others)?
· What should you do if your personal information changes?
· For how long is your personal information retained by us?
· What are your rights under data protection laws?
· How can you opt out of marketing communications?
Changes to this privacy notice
We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – www.1stgear.uk
1st Gear Driver Training and our Data Protection Officer
We’re 1st Gear Driver Training. We are a data controller of your personal data.
We have a nominated data protection officer (“DPO”). You can contact the DPO using the details below, marking it for the attention of the DPO or by using the enquiry link on our website.
2. What kinds of personal information about you do we process?
Personal information that we’ll process in connection with all of our products and services, if relevant, includes:
· Personal and contact details, such as title, full name, contact details and contact details history including your address for payment and lesson pickup
· Your date of birth, gender and/or age
· Your nationality, if needed for the product or service
· Family members, if relevant to the product or service
· Records of your contact with us such as via the phone number of our booking and contact service and, if you get in touch with us online using our online services, details such as name, email address and phone numbers.
· Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used.
· The usage of our products and services, training history, number of lessons and level achieved (and details related to this).
· Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. Offers may include training related products and offers from associates and partners.
· Vehicle information, such as insurance, MOT and road tax (if training is to take place in your vehicle)
· Driving school assessment, including feedback and analysis of your instructors performance and documentation
· Information about your health or special needs and requirements, if relevant and disclosed to allow us to correctly provide a product or service, or to look into the provision of reasonable adjustments
· Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK. This is directly related to your right to drive as a visitor or the need to obtain a UK driving licence
· Third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction
3. What is the source of your personal information?
We’ll collect personal information from the following general sources:
· From you directly, and any information from family members, associates or beneficiaries of products and services
· Information generated about you when you use our products and services
4. What do we use your personal data for?
We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:
· Assessing an application for a product or service, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms
· Managing the product or service you have with us
· Updating your records, tracing your whereabouts and recovering debt
· Managing any aspect of the product or service
· To make decisions on whether to offer you a product or service, or the price, payment method, risk or terms of it
· To perform and/or test the performance of, our products, services and internal processes
· To improve the operation of our business
· To follow guidance and best practice under the change to rules of governmental and regulatory bodies
· For management and auditing of our business operations including accounting
· To monitor and to keep records of our communications with you and our staff
· For market research and analysis and developing statistics
· For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook and Google services). Offers may relate to any of our products and services and any other services or offers from time to time
· To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
· To develop new products and services and to review and improve current products and services
· To comply with legal and regulatory obligations, requirements and guidance
· To provide insight and analysis of our customers either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our business
5. What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:
· Where it is needed to provide you with our products or services, such as:
· a) Assessing suitability of a product or service you wish to purchase from us, including to consider whether or not to offer you the product, the price, the payment methods available and the conditions to attach
· b) Managing products and services you hold with us, or an application for one
· c) Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
· e) All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts
· f) For some of our profiling and other decision making to decide whether to offer you a product and/or service, particular payment method and the price or terms of this
· Where it is in our legitimate interests to do so, such as:
· a) Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
· b) To perform and/or test the performance of, our products, services and internal processes
· c) To follow guidance and recommended best practice of government and regulatory bodies
· d) For management and audit of our business operations including accounting
· f) To carry out monitoring and to keep records of our communications with you and our staff
· h) For market research and analysis and developing statistics
· i) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook and Google services)
· j) Subject to the appropriate controls, to provide insight and analysis of our customers either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses
· k) For some of our profiling and other decision making
· l) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
· To comply with our legal obligations
· With your consent or explicit consent:
· a) For some direct marketing communications
· b) For some of our profiling and other decision making
· c) For some of our processing of special categories of personal data such as about your health or if you are a vulnerable customer
· For a public interest, such as:
· a) Processing of your special categories of personal data such as about your health or if you are a vulnerable customer
6. When do we share your personal information with other organisations?
We may share information with the following third parties for the purposes listed
· Governmental and regulatory bodies such as HMRC and the Driver and Vehicle Standards Agency (DVSA)
· Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
· Market research organisations who help us to develop and improve our products and services
7. How and when can you withdraw your consent?
Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.
8. Is your personal information transferred outside the UK or the EEA?
We’re based in the UK and personal data should be kept within the European Economic Area. Sometimes your personal information may be transferred outside the European Economic Area by the cloud provider. If they do so we make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
9. What should you do if your personal information changes?
You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.
1. Do you have to provide your personal information to us?
We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing personal information is optional, we’ll make this clear.
1. Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.
We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
1. For how long is your personal information retained by us?
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
· For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
· For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or as long as external regulatory bodies may require the information
· Retention periods in line with legal and regulatory requirements or guidance.
1. What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
· The right to be informed about the processing of your personal information
· The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
· The right to object to processing of your personal information
· The right to restrict processing of your personal information
· The right to have your personal information erased (the “right to be forgotten”)
· The right to request access to your personal information and to obtain information about how we process it
· The right to move, copy or transfer your personal information (“data portability”)
· Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.
14. Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.
1. What are your marketing preferences and what do they mean?
We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences.
You can opt out of any email or text marketing by contacting us via our web page.
If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the contact us section of our website marking it for the attention of the DPO.