Privacy
INTRODUCTION
Welcome to Splend’s Privacy Notice. At Splend, we want you to know that we have your best interests at heart and in this Privacy Notice, we give you information on how we collect and process your personal data when you use our website or mobile applications, take part in any of our competitions, sign-up as a customer with us, apply for a job with us or are a service provider to us.
As data protection is really important to Splend, we may provide you with additional data privacy notices or information that is specific to your situation – and if we do, you need to read that additional information alongside this Privacy Notice (which is our key document and will always apply).
Splend, as an organisation, is made up of different legal entities and together all of these entities form a group. This Privacy Notice applies to the entire group.
As Splend takes managing your personal data seriously, we have a team who are responsible for overseeing the management and security of your personal data as well as answering any questions that you have about this Privacy Notice. If you would like to get in touch with this team, please kindly contact privacy@splend.com.
We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint at any time to your local data protection regulator.
This Privacy Notice is kept under regular review and was last updated in August 2019.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
A) Different kinds of personal data
In general, we collect, use, store and transfer different kinds of personal data and we’ve grouped them together below for you:
Contact Data includes billing address, delivery address, email address and telephone numbers.
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol 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 this website. Where you are a customer with us, it also includes data on your driving and the locations that you have travelled to with our vehicle (as our vehicles are installed with devices that track this data).
Profile Data includes your username and password, agreements signed with you (such as our subscription agreements), your interests, preferences, feedback and survey responses.
Transaction Data includes details about payments from you and other details of products and services you have registered for with us.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 Notice.
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).
We do collect personal data that is to do with driving-related offences and criminal convictions that our drivers have received before they are fully able to become customers with us. We only obtain and process this data when we have a lawful basis in which to do so (i.e. consent has been given to us by the driver for us to obtain this data).
Our products and services are not intended for children and therefore, we do not knowingly collect data relating to children.
B) Our relationship with you
The personal data that we collect from you depends on our relationship with you. Below we’ve made a chart which explains the personal data that we collect, how we collect this data and what our legal basis is for collecting it (as we will only collect and process your personal data when the law allows us to do so).
The personal data that we collect from you depends on our relationship with you. Below we’ve made a chart which explains the personal data that we collect, how we collect this data and what our legal basis is for collecting it (as we will only collect and process your personal data when the law allows us to do so).
| Who are you? | What data do we collect about you? | How do we collect this personal data about you? | What’s our legal basis for collecting this personal data? |
| I am using the Splend websites and/or applications and I am keen to find out more about what Splend can offer. | - Technical Data and Usage Data (for tracking purposes). - Identity Data, Contact Data and Marketing and Communications Data (if you enter into a competition, promotion or survey or sign-up for more information etc.). | - Automated technologies – As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. - Direct interactions – If you decide to contact us through our website or through other means, you will be directly providing us with your personal data. | 1. Consent, in that you are choosing to provide us with your details so that we know to contact you about your query. 2. Necessary for our legitimate interests (i.e. for running our business, provision of services, to develop our business and to inform our marketing strategy). |
| I am a Splend customer (i.e. a driver that has entered into or is in the process of entering into a contractual agreement with Splend). | - Technical Data and Usage Data (for tracking purposes and information on your driving). - Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data (for when you enter into a formal relationship with us for a service or product). | - Automated technologies – As you interact with our website (and/or products), we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. - Direct interactions – If you decide to contact us through our website or through other means, you will be directly providing us with your personal data. - We may receive personal data about you from third-parties (as detailed below) and public sources. | 1. Performance of a contract with you. 2. Necessary for our legitimate interests (i.e. to recover debts due to us, to keep records to develop our business strategy). 3. Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs). |
| I am a candidate applying for a job with Splend (and/or am subsequently in the process of signing an employment contract with Splend). | - Technical Data and Usage Data (if you apply through our website). - Identity Data and Contact Data (information submitted as part of your application). | - Automated technologies – As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. - Direct interactions – If you decide to apply for a job at Splend, you will be directly providing us with your personal data. - Third-parties or publicly available sources – We may receive personal data about you from various third-parties (such as recruitment agents or your referees) and public sources. | 1. Consent, in that you are choosing to provide us with your details so that we know to contact you about a vacancy. 2. Performance of a contract with you. |
| I am a service provider to Splend. | - Technical Data and Usage Data (for tracking purposes) - Identity Data and Contact Data (if you register your interest). | - Automated technologies – As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. - Direct interactions – If you agree to provide us with a service, we will hold the personal data of your staff that have engaged with us. | 1. Performance of a contract with you. 2. Necessary for our legitimate interests (i.e. for running our business). 3. Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs). |
Please contact us on privacy@splend.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above.
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.
C) If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods and/or services). In this case, we may have to cancel goods and/or services you have with us – but we will notify you in advance.
D) Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If this does occur and you wish to get an explanation as to how the processing for a new purpose is compatible with the original purpose, please contact us on privacy@splend.com. If we need to use your personal data, however, for an entirely unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DO WE DISCLOSE YOUR PERSONAL DATA TO OTHERS AND IF SO, WHO?
We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal third-parties such as those within our group that are based outside of the EEA such as in Australia, Canada and/or Mexico.
External third-parties such as:
Potential and existing customer tracking and engagement providers
for us to be able to track our engagement with potential and existing customers as well as be able to communicate with them through different methods (such as online chat, text and telephone).
On-demand driving apps
for us to help potential customers when they need assistance in submitting their application to for these apps.
Organisations that liaise with local regulatory driving bodies
for us to check the identity and driving history, including any driving related offences and/or criminal convictions received by our potential customers.
Telematics device and software providers – for us to be able to monitor engine data, driving behaviour and vehicle location.
Payment service providers – for us to process any payments made by our customers to us.
Insurers and claims processors – for us to deal with any accidents or vehicle issues that our customers face.
Vehicle servicing, maintenance and repair organisations – for us to ensure that the vehicles that our customers are driving are roadworthy.
Candidate tracking, assessment and background screening organisations – for us to manage and evaluate candidates that are applying for vacancies with us and to confirm their details and credentials.
Technology companies that provide us with desktop and cloud-based products – for us to conduct our business and back-up data (which may include your personal data) whilst you are reviewing our website, applying to be our customer, applying for a vacancy with us or acting as one of our suppliers.
Professional advisers such as law firms, banks, and accountancy firms – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).
Regulators and other governmental authorities – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).
Third-parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
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, except for when such third-parties are regulators and other governmental organisations.
IS YOUR DATA EVER TRANSFERRED OUTSIDE OF THE EEA?
We share your personal data within the Splend group and with some of our third-party suppliers. This will involve transferring your data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us on privacy@splend.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
HOW LONG DO WE RETAIN YOUR DATA?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see “what are your legal rights?” below for further information.
In some circumstances we will 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.
WHAT ARE YOUR LEGAL RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data which we have summarised for you below
| Legal right | What’s it all about? |
| Request access to your personal data (commonly known as a “data subject access request”) | This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. |
| Request correction of the personal data that we hold about you | This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. |
| Request erasure of your personal data | This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. |
| Object to processing of your personal data | This applies when we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
| Request the restriction of processing of your personal data | This enables you to ask us to suspend the processing of your personal data in the following scenarios: - If you want us to establish the data’s accuracy. - Where our use of the data is unlawful, but you do not want us to erase it. - Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. - You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. |
| Request the transfer of your personal data to you or to a third-party | We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |
| Withdraw consent at any time where we are relying on consent to process your personal data | This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. |
If you wish to exercise any of the rights set out above, please contact us on privacy@splend.com.
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity. 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 1 month. Occasionally it could take us longer than 1 month 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.
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, 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.
COOKIES
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 our Cookies Notice.
THIRD-PARTY LINKS
Our websites and applications 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 websites and applications, we encourage you to read the privacy documentation of every website you visit.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes. You can ask us or third-parties to stop sending you marketing messages at any time by contacting us at any time on privacy@splend.com and withdrawing your consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g. as we may be required to contact you about a payment due).
Please also note that if you contact us via our website and specifically complete our “sign-up” form for our services, we will contact you and arrange to discuss our services with you. We would be relying on it being our legitimate interest to respond to your communication. We will not send you marketing communications unless we have obtained your express opt-in consent or if you do subsequently purchase our services and do not opt out of receiving our marketing communications.