This document explains how My Four Wheels processes information about you which is personally identifiable (“Your Information”) when you use any of our apps or websites (“My Four Wheels”), whether you are a driving instructor, learner driver or visitor.
If you have any queries about how we use Your Information or have a complaint, please contact us at email@example.com
GENERAL DATA PROTECTION REGULATIONS
Where personal information is provided by you as part of a subscription service, or for requesting information of one of our products, that information will be held in accordance with the terms of the EU General Data Protection Regulations (GDPR).
WHY DO WE NEED TO OBTAIN PERSONAL INFORMATION ABOUT YOU?
Modern information and communication technologies play a fundamental role in the activities of an organisation like My Four Wheels Limited.
To allow us to recognise what products you have purchased or enquired to, we need to be able to identify you. We do this with your personal information.
Where this data is collected, it will only be used in the lawful context of providing the services to which you have enquired or purchased, namely in the delivery of Road Safety and Driver Education via our products.
WHAT INFORMATION DO WE COLLECT?
We will collect the following:
- Name (first, any middle names and family name);
- Postal Address;
- Email address;
- Telephone number;
- Driving licence details
- Date of Birth
- DVSA Registration Details
- CRB check information
We will contact you using data we collect. We would expect any 3rd party providers we use to deliver the service and/or product, by using any or of the above data.
WHAT WILL WE DO WITH THIS INFORMATION?
Your Information will only be used in line with the GDPR guidelines. We only collect information we believe we need to help identify you and to help deliver the product or service you are interested I taking / have taken.
We may also introduce you to you other My Four Wheels products and 3rd party products that we believe you will be interested in and/or will help us in the delivery of the product/service you have purchased or enquired about or we are contractually obligated to provide.
This may be educational, instructional or promotional. We will contact you using all and/or any of the above means. We would expect any 3rd party providers we use to deliver the service and/product, to use all and/or of the above means.
WILL WE PASS MY INFORMATION TO 3RD PARTIES?
In the process of delivering the above where we are contractually obligated, it may be necessary to pass your Information to affiliates such as ‘franchise providers’, ‘insurance providers’ for example. Where we do, we insist that these affiliates also comply with this policy and GDPR. Rest assured, we won’t sell you data to any unaffiliated parties.
Where we are ‘contractually obligated’ to deliver a service that relies on these 3rd parties being passed your information, we are processing your information for our lawful basis of ‘contractual obligation’ and therefore we do not necessarily need your permission to do this – see ICO GDPR Guidelines. However, we respect your right to ask us to not do this and will release you from the contract if you so wish.
HOW LONG WILL YOU KEEP MY INFORMATION?
We will keep Your Information for as long as necessary but not usually more than 7 years. This the length of time we’re obliged to keep certain information in accordance with HMRC guidelines. We believe our customers will still wish to receive information from us regarding products we offer which means we need to keep data for accounting, tax and training purposes.
HOW WILL YOU USE MY INFORMATION?
We will only use your Information for the purpose of delivering the product/service you have purchased/enquired about and any value added additional products or service we think will benefit you.
We store your information in our Customer Relationship Management (CRM) system. This is hosted on our own secure server and protected with our own SSL Certificates.
All staff users that access the CRM to process your information have agreed to adhere to our Data Protection guidelines as described in this policy. Staff GDPR policy
All of our equipment used to access your data is in a secure office. Access is restricted to just My Four Wheels staff (and cleaning/contracted staff supplied to service the office that have agreed to their own GDPR guidelines). The equipment is password protected and access to the CRM is password protected.
Where I.T support providers have access to your personal information, they too follow the guidelines as outlined in this policy.
Any ‘physical’ information we may obtain (i.e. a signed document or contract – where applicable) is stored securely online or in a lockable filing cabinet within a secure office, to which only specified staff have access. The keys are stored in a secure place within the secure office.
Your information will not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection and adherence to GDPR.
WHAT IF YOU WANT TO SEE WHAT INFORMATION we HAVE?
You can see all personal information we hold by logging into the product you have purchased or by emailing us at firstname.lastname@example.org.
You can reply to any email you have received from us asking for the information we have.
We will contact you to identify you and we will provide you with a readable copy of the personal data which we keep about you, almost instantaneously online. We will provide the information without any charge.
You are able to challenge the data that we hold about you and, where appropriate, you may have the data: erased, rectified, amended or corrected. However, if we are contractually obligated to provide a service/product, then we can refuse any right to erasure under the ‘Right to Erasure’ regulations. This is to allow us to comply with our legal obligations in delivering the contract.
We will inform you without undue delay and within one month of receipt of the request or our position to refuse your request and the reasons we are not taking action, your right to make a complaint to the ICO or another supervisory authority; and your ability to seek to enforce this right through a judicial remedy.
WHO ARE WE?
We are My Four Wheels.
We are based in England.
Our principal activity is: Road Safety and Driver Education
USE OF ‘COOKIES’ AND ANALYTICS
If you are a user with general public and anonymous access the Websites do not store or capture personal information, but merely logs the user’s IP address that is automatically recognised by the web server.
We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
The only cookies in use on our site are for Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.
Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.
PROVIDING VISITORS WITH ANONYMOUS ACCESS
You can access our website’s homepage and browse our site without disclosing your personal data.
AUTOMATIC COLLECTION OF INFORMATION
We do not automatically log personal data, nor do we link information automatically logged by other means with personal data about specific individuals.
1) Technical administration of the website: We do not automatically log any other personal data.
2) Data Collection and Purpose Specification
We collect the personal data that you may volunteer while using our services.
We do not collect information about our visitors from other sources, such as public records or bodies, or private organisations.
The only information we collect is for the administration of our services. This information is as follows:
First name: Family name: Postal address: post-code: E-mail address; Telephone Number
The information is not used for any purpose other than:
Internal web administration (technical) and customer administration
Contacting and distributing information to fee subscribed members
We do not collect or use personal data for any purpose other than the purposes indicated above.
We do not knowingly collect personal data from children.
If it is discovered that information has been provided by anyone under the age of 14 years that information is immediately deleted.
CONFIDENTIALITY / SECURITY
We do not give visitors to our websites the option of using a secure transmission method to send us their personal data when applying for membership.
All monetary transactions are conducted through a secure third-party web server (Pay-Pal/WorldPay/Stripe).
We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:
Improper use or disclosure
Unlawful destruction or accidental loss
All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors’ personal data. We ensure that your personal data will not be disclosed to State institutions and authorities except if required by law or other regulation.
If there is any conflict between these terms and specific terms appearing elsewhere on our website, then the latter shall prevail. If any of these terms are determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these terms are intended to be effective, then to the extent and within the jurisdiction in which that term is illegal, invalid or unenforceable, it shall be severed and deleted from these terms and the remaining terms shall survive, remain in full force and effect and continue to be binding and enforceable.
These terms shall be governed by and interpreted in accordance with the laws of England and Wales, and the EU GDPR. © My Four Wheels 2019 All rights reserved
No part of this web site may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without prior written permission. Unauthorised reproduction may result in prosecution or action for damages