2. WHO WE ARE

2.1       CCL and SSL are wholly owned subsidiaries of LSL.

2.2      The relevant group entity that you owns and operates the website and/or application that you are using is the data controller for the purposes of the Data Protection Legislation (as defined in paragraph and shall be responsible for your personal data.  When this Privacy Policy uses the term “we”, it refers to that entity

2.3       Our representative Privacy Manager (who is responsible for overseeing questions in relation to this Privacy Policy) can be contacted at privacy@crownsds.com.

2.4       We respect your right to privacy and will only process personal information about you in accordance with the “Data Protection Legislation” which for the purposes of this Privacy Policy shall mean:

(i)     unless and until the GDPR is no longer directly applicable in the UK, the retained General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”), as amended or updated from time to time and then

(ii)   any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. WHAT WE MAY COLLECT

3.1       “Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is no longer identifiable.

3.2       The extent and type of personal data that we may collect from you will ultimately depend on your relationship with us (whether as a customer, driver or a website visitor). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (however note that certain of the categories below may not apply to you if you are a driver, customer or website visitor):

·         Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address, and phone number. In certain circumstances, we may also require you to provide us with an image of yourself.

·         Vehicle Data includes vehicle registration plate and insurance policy details (which may contain Identity Data)

·         Contact Data includes billing address, invoicing address, email address and telephone numbers.

·         Financial Data includes bank account and payment card details.

·         Transaction Data includes details about payments and other details of our Services you have purchased from us.

·         Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website(s) and/or application(s).

·         Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback and survey responses.

·         Usage Data includes information about how you use our website(s) and/or application(s).

·         Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·         Interaction Data includes any information that you might provide to any discussion forums on our website(s) and/or application(s).

·         Cookies. Like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Cookies” section at paragraph 7 below for further information.

·         Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites and/or applications we operate or through the services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected via our website(s) and/or application(s). We may also receive data from third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers (such as Google Analytics), and search information providers (including SEOMoz, Inc and SEMrush SEO)).

·         Analytics. If you are a new customer, we may keep a record of your activities on the site to enable us to generate analytical data of customer usage in comparison from new users to current users. We may also use third-party analytics services (such as Google Analytics) to evaluate your use of the our website(s) and/or application(s) (if applicable), compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our website(s) and/or application(s) and internet usage. These third parties use cookies and other technologies to help analyse and provide us with the data. By accessing and using the our website(s) and/or application(s), you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3       We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be 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 Usage Data to calculate the percentage of users accessing a specific website feature. However, 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 Policy.

3.4       We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through your use of our application(s) and/or website(s). We do collect information about criminal convictions and offences, such as DBS assessments and DVLA vehicle licence checks, in the event of suspicion of criminal activity.

3.5       If we receive personal information in the course of providing our Services to you about another data subject, whilst we will use every effort to bring this Privacy Policy to their attention (using the details you have provided) (e.g. by linking to this Privacy Policy using in our automated emails to the recipient) we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to their attention prior to you providing personal data on their behalf and you have obtained their consent in the process.

3.6       In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

3.7       Our websites and applications are not intended for children and we do not knowingly collect data relating to children.

3.8       It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

4.1       In accordance with our obligations under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.

4.2       We will only process your personal data if at least one of the following basis applies:

(a)  you have given consent to the processing of your personal data for one or more specific purposes;

(b)  the processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

(c)  the processing is necessary for compliance with a legal obligation to which we are subject;

(d)  the processing is necessary to protect the vital interests of you or of another natural person;

(e)  the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

(f)   the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

5. HOW WE MAY COLLECT AND USE YOUR PERSONAL DATA

5.1       We may collect, store and use your personal information by way of different methods to collect data from and about you including through:

(a)  Direct interactions. You may give us your information by filling in forms via our our website(s) and/or application(s) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(i)        present website content;

(ii)       use any of our services (including any of our applications and/or websites);

(iii)     create an account on our website(s) and/or application(s);

(iv)     use our services or subscribe to our publications;

(v)       request marketing to be sent to you;

(vi)     enter a competition, promotion or survey; or give us some feedback.

(b)  Indirect interactions. You may give us your personal information through indirect interactions such as your browsing activity while on our website(s) and, where applicable, our application(s) (see the “Cookies” section below).

5.2       We may use this personal information in the following ways:

(a)  to personalise your website experience and to allow us to deliver the type of content and product offerings in which you are most interested;

(b)  to administer a contest, promotion, survey or other site feature;

(c)  to present website content effectively to you;

(d)  to provide information, and services that you request, or (with your consent) which we think may interest you;

(e)  to carry out our contracts with you;

(f)   to provide the relevant services to you [or to enable you to provide delivery services]; or

(g)  to tell you our charges [or the payments you will receive] and to process such payments.

6. MARKETING

6.1       We would like to send you information about our products and services which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

6.2       We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you register for the first time, or tick the relevant box within your profile settings.

6.3       If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

(a)  contacting us at info@crownsds.com;

(b)  using the ‘unsubscribe’ link in emails or ‘unsubscribe’ in mobile texts; or

(c)  updating your marketing preferences on your profile page.

6.4       For more information on your rights in relation to marketing, see ‘Your rights’ below.

7. COOKIES

7.1       We use cookies to distinguish users and improve our websites.

7.2       You can set your browser to refuse all or some 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.

7.3       For details of the cookies we collect, please refer to our cookie policies: (a)        in respect of cookies collected via the CCL website, please refer to https://www.crownsds.com/cookies/.

8. TRANSFER OF YOUR INFORMATION OUT OF THE UK AND EEA

8.1       We may transfer your collected data to storage outside the United Kingdom (UK). If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR.

8.2       Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a)  we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

(b)  where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

8.3       Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. KEEPING YOUR PERSONAL INFORMATION SECURE

9.1       Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our website(s) and/or application(s). 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.

9.2       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.

9.3       If you are a customer, any payments made by you will be encrypted.

9.4       We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

9.5       Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

9.6       If we give you a password upon registration on our website(s) and/or application(s), you must keep it confidential. Please do not share it.

9.7       We will keep personal data for as long as is necessary to fulfil the purposes we collected it for. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to and 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.