Data privacy notice for customers of Co Cars
1. Definitions
- Data controller – a controller determines the purposes and means of processing personal data
- Data processor – a processor is responsible for processing personal data on behalf of a controller
- Data subject – a natural person
- Categories of data
- Personal data – GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR); for example name, passport number, home address or private email address; online identifiers include IP addresses and cookies
- Special categories personal data – GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR); the special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual; other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs
- Aggregated Data – data derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity; for example, we may aggregate your website usage data to calculate the percentage of users accessing a specific website feature, or use your postcode to map where people interested in us live
- Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data
2. Who are we?
Co Cars Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: The Generator Hub, The Gallery, Kings Wharf, The Quay, Exeter, EX2 4AN. For all data matters contact our Data Protection Officer at drive@co-cars.co.uk.
3. The purposes of processing your personal data
We use your personal data for the following purposes:
- To satisfy our vehicle insurance requirements
- To provide a car club service to you and ensure operational reliability
- For billing and debt management
- To optimise our customer service delivery
- To avoid discrimination
- To send you service messages
- To contact you about operational or financial matters
- To keep you informed about news, events and promotions
You may give us information about you by filling in forms on our website www.co-cars.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our car club service or enter a competition, promotion or survey, and when you report a problem with our website, booking system or vehicles.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
4. Categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data: name, address, date of birth, gender or gender identity, email address, phone numbers, copy of driving licence photo card, DVLA licence summary, financial & banking & credit card information, trip data (vehicles used, distances travelled, trip start and end times*), GPS location history*, correspondence
- Special categories of data: health and disability information where relevant
*Our vehicles are equipped with a vehicle telematics system provided by Convadis AG Switzerland. This system provides us with access to location information, mileage and diagnostic reporting of vehicles (“Telematics Data”), as permitted by law. This data is processed only within the European Economic Area.
5. What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
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- Our lawful basis for processing your general personal data is that it is necessary for the performance of a contract with you (the data subject) or to take steps to enter into a contract. The contract arises from you agreeing to use our service in accordance with the Terms and Conditions we have set out from time to time.
- For the purpose of contacting you via email about events, activities and promotions, we are processing your data because we have a legitimate interest. We have carried out a Legitimate Interest Assessment taking into account the interests or fundamental rights or freedoms of the data subject.
- Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data is that the data subject has given explicit consent to the processing of those personal data for one or more specified purposes.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared with Cantamen GmbH and Technology for Shared Transport Ltd, both of which are data processors on behalf of Co Cars Limited. We may also share your data for the specific purpose of improving service standards, recovering outstanding payments or in relation to insurance claims.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will get your express opt-in consent before we share your personal data with any third party for their own purposes.
7. How long do we keep your personal data?
We keep your personal data for a period of 12 months after you have given notice to end your membership of Co Cars Limited, in case there are any legal claims or complaints.
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.
8. Providing us with your personal data
We require your personal data as it is a contractual requirement, or a requirement necessary to enter into a contract with us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. International Transfer of Data
We transfer and store data outside of the European Economic Area (EEA). All data processing services we use undergo independent third-party audits to provide verification of security, privacy, and compliance controls. We use the services listed below, and details for their privacy can be found by following the link shown:
- GSuite and Google Cloud – https://cloud.google.com/security/gdpr
- Microsoft 365 – https://privacy.microsoft.com/en-GB/privacystatement
- Dropbox – https://www.dropbox.com/en_GB/security/GDPR
- MailChimp – https://mailchimp.com/legal/privacy
- GoCardless* – https://gocardless.com/downloads/legal/privacy-policy-v0417-1.pdf
*Whilst GoCardless will take all steps reasonably necessary to ensure that your data is treated securely, GoCardless cannot guarantee the security of your data transmitted to its website, and any transmission is at the data subject’s own risk.
11. Automated Decision Making
We do not use any form of automated decision making at Co Cars Limited.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. Cookies and links
Our bookings website uses Cookies to recognise you. 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. For more information about the cookies we use, please see www.co-cars.co.uk/cookie-policy
Our 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.
14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
15. 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. 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.
While we will take all reasonable steps to maintain the security of our website, you should understand that the open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. Therefore, we cannot and do not guarantee that personal information you provide will not be intercepted by others and decrypted.
16. Queries, requests and complaints
To exercise all relevant rights, raise queries and make requests or complaints please in the first instance contact our Data Protection Officer at drive@co-cars.co.uk.
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, 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 30 days. Occasionally it may take us longer than a 30 days 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.
If we do not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.