Fleck’s Motorhome Hire understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Fleck’s Motorhome Hire
Data Protection Officer: Mike Fletcher
Email address email@example.com
Telephone number: 07889980502
Postal Address: 12 Watersheddings way Oldham OL42RE
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us:
· Date of birth;
· Email address;
· Telephone number;
· Payment information;
· National Insurance Number;
· Driving Licence information;
· Credit card information;
Your personal data is also obtained from the following third party:
· DVLA – driving licence details;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
· Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
· Personalising and tailoring our services for you.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information either by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the unsubscribe by writing to us by post or email or telephone).
· Assessing your continuing eligibility to drive our vehicles.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone, text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We do not use the any automated systems for carrying out decision-making or profiling.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
· Your contact details used for marketing will be retained until you opt to unsubscribe;
· Your personal details contained within a hire agreement will be retained whilst you are a customer of Fleck’s Motorhome hire and for 7 years after you cease to be a customer to ensure HMRC rules for transaction history are complied with.
8. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
· Ensuring that any service providers that we use to process your data, such as Microsoft or Dropbox, have polices in place to ensure that data is kept as safe and secure as it would be in the UK.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Ensuring desks are clear of any documentation with personal data when the office is empty.
· All documents with personal data are stored in filing cabinets in buildings that are locked when empty.
· Any data storage devices or services that are used for data processing are encrypted, as are the communications between those devices and services.
· All computers used for processing personal data are protected by passwords to prevent casual access.
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for marketing purposes. This includes any future subsidiaries and any future holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply services to you on our behalf. These may include payment processing, vehicle insurance, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
· Evelon Merchant Banking, for the provision of payment processing services.
· LV or equivalent broker for the provision of motor insurance services for our vehicles.
· DVLA, Swansea for the provision of driving licence data
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We will share your data with the Police and associated agencies if it is required for the prevention or detection of a crime.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Mike Fletcher):
Email address; firstname.lastname@example.org
Telephone number: 07889 980 502
Postal Address: 12 Watersheddings Way Oldham OL42RE
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website.