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DRIVEELECTRIC Privacy Policy

BACKGROUND:

DriveElectric (A trading style of Fleetdrive Management Limited) 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 everyone who visits this website, www.drive-electric.co.uk (“Our Site”) 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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when registering an interest with DriveElectric, or when undertaking to engage with any of our products and services.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2. Information About Us

Our Site is owned and operated by DriveElectric a limited company registered in England under company number : 02776514.

Registered address: Unit 1, Harleyford Marina, Henley Road, Marlow, Bucks, SL7 2DX.

VAT number: 625950821

Data Protection Officer: Melanie Potter

Email address: mel@drive-electric.co.uk

Telephone number: 07887720018

Postal address: DriveElectric Harleyford Marina, Henley Road, Marlow, Bucks, SL7 2DX.

We are regulated by the Financial Conduct Authority, permission number 678978.

We are a member of British Vehicle Renting and Leasing Association, registration number 1398.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) 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 data covers 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.

5. What Are My Rights?

Under the Data Protection Legislation, 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 Policy 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 15.

The right to access the personal data we hold about you. Part 13 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 15 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 hold. Please contact us using the details in Part 15 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 withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

Rights relating to automated decision-making and profiling.

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 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

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.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some, or all of the data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ personal data or personal data relating to children.

Data Collected	How We Collect the Data
Identity information including name, title, date of birth and gender.	Customer engagement methods and other documents submitted by customers during the course of business.
Contact information including address, email address, telephone numbers.	Customer engagement methods and other documents submitted by customers during the course of business.
Business information including business name, job title, profession.	Financial proposal submissions and other documents submitted by customers during the course of business.
Payment information including bank account details, financial records and outgoings.	Customer engagement methods, financial proposals and other documents submitted by customers during the course of business.
Profile information including purchase history, vehicle details and charger details.	Customer’s previous activities and dealings when engaging with DriveElectric.
Technical information including IP address, browser type and version, operating system and platform.	Web analytics and cookies collected from online engagement processes and web pages.
Data from third parties including additional technical information, financial details such as credit scores and history.	Supplied via third parties when relevant and necessary to conduct business.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering your interest on our site.	Identity, contact and technical information.	Consent supplied by the user and the legitimate interests of DriveElectric to engage in business with such users.
Providing and managing your Account.	Identity, contact, business and profile information.	Consent & legitimate interests, contractual Requirements.
Providing and managing your access to Our Site.	Identity, profile and technical information.	Consent & legitimate Interests.
Personalising and tailoring your experience on Our Site.	Identity, profile and technical information.	Consent & legitimate Interests.
Administering Our Site.	Identity, profile, technical information.	Consent supplied by the user, legitimate interests.
Administering our business.	Identity, contact, business, payment, profile, technical information and data from third parties.	Legitimate interests, legal and contractual obligations.
Supplying our products and services to you.	Identity, contact, business, payment, profile and technical information, and data from third parties.	Consent, legal and contractual obligations.
Managing payments for our products and services.	Identity, contact, business and payment information, and data from third parties.	Consent, legitimate interests, legal and contractual obligations.
Personalising and tailoring our products and services for you.	Identity, contact, business, profile and technical information, and data from third parties.	Consent, legitimate interests.
Communicating with you.	Identity, contact, profile and technical information and data from third parties.	Consent, legitimate interests, legal and contractual obligations.

Our Legitimate Interests Include:

• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.

• Seeking your consent when we need it to contact you.

• Developing new products and services, and what we charge for them.

• Defining types of customers for new products or services.

• Fulfilling our legal and contractual duties, and doing so in an efficient manner.

• Complying with regulations that apply to us.

• Developing and improving how we deal with financial crime, and adhering to accounting and taxation rules.

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, telephone, text message and post with information, news, and offers on our products 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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.

The following automated decision-making method(s) may be used:
- The usage of automated systems to make decisions based on credit scoring and history to underwrite funding.
The following automated profiling may take place:
- The direction of marketing material and offers based upon profile information and other data to provide personalised communications that match consumer expectations.
- Data and analytics processing as part of services provided by DriveElectric.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

8. 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.

This includes satisfying any legal, accounting or reporting requirements, and to protect our business.

This is usually 7 years from the date that any agreement between us ends.

In some circumstances we may anonymise or pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may also put your personal data beyond use. In these instances, we may use or hold this information indefinitely without further notice to you.

9. How and Where Do You Store or Transfer My Personal Data?

We will store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

We will store or transfer some of your personal data within the European Economic Area (the “EEA”). This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

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:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

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 may share your personal data with other companies in our group to enable effective business practices and development. This includes subsidiaries.

We may sometimes contract with the following types of third parties to supply certain products and services:

Recipient	Activity Carried Out	Sector	Location
Manufacturers	Procurement	Vehicle, Electronic	EEA
Funders and Financial Institutions	Financial transactions and undertakings	Financial	UK
Suppliers	Procurement and logistics	Vehicle, Electronic, Miscellaneous	EEA
Data processers	Data storage and management	Information Technology	EEA
Installers	Fitting and Installation	Technical	EEA

If any of your personal data is shared with 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, as described above in Part 9.

If any personal data is transferred 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 Data Protection Legislation, as explained above in Part 9.

11. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us you may do by unsubscribing using the links provided in our emails, at the point of providing your details and as part of managing your Account with us.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

For more information, see Part 14.

13. 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 15.

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 two 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.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt at the bottom of the page requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.

15. 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:

Email address: support@drive-electric.co.uk

Telephone number: 01628 899720

Postal Address: DriveElectric, Harleyford Marina, Henley Road, Marlow, Bucks SL7 2DX

16. Changes to this Privacy Policy

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 immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated in December 2018.

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