- Consent to installation of the App
- How you can withdraw consent
- Third party links
- The data we collect about you
- Special categories of personal data
- How is your personal data collected?
- How we use your personal data
- Purposes for which we will use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Consent to installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in The Data We Collect About You and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy How We Use Your Personal Data.
YES I consent to the installation of the App for the purposes of managing my vehicles and purchasing services in relation to ownership of my vehicles and their insurance and financing.
NO I do not consent to the installation of the App.
2. How you can withdraw consent
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at firstname.lastname@example.org but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
Location Data There are no location enabled services or services which are dependent upon knowing your location in this App.
Pace Cloud Limited (we) are committed to protecting your personal data and respecting your privacy.
This policy applies to your use of:
- The CarCloud Community app version 3 mobile application software (App) available on the App Store and Google Play and our website carcloudcommunity.co.uk (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
- Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy is provided in a layered format so you can click through to the specific areas set out below.
This version was last updated on 24th May 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
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 our relationship with you.
5. Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
Please check these policies before you submit any personal data to these websites or use these services.
6. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data, which includes billing address, delivery address, email address and telephone numbers.
- Driving Licence Data: your driving licence number and the length of time you have held a driving licence as well as a copy of your photocard driving licence.
- Vehicle Data, which includes details of your vehicles namely make, model, description, registration number and photographs, their MoT status and renewal dates, licencing status and renewal dates and information regarding servicing and repairs including next service dates and mileages and copies of service and repair invoices MoT certificates as well as related information and documents.
- Financial Data, which includes bank account and payment card details, any car finance agreement, including car finance monthly payments, outstanding balance, APR interest rate and the term of such agreement as well as information regarding your credit scoring if needed for enquiries relating to car finance.
- Insurance Data, which includes information needed to enable us to help you obtain insurance quotations and which in addition to the other data we collect includes details of where and how your car is located and stored when not used, your existing insurance terms including your no claims bonus, details of any accidents in which you have been involved and details any driving related convictions and certain road traffic offences and fixed penalties you have incurred, copies of your insurance certificates and policy documents and special terms imposed or required by existing or previous vehicle insurers.
- Transaction Data, which includes details about payments from you and details of in-App purchases and details of out of App purchases you make as a result of introductions or referrals form the App.
- Device Data, which includes the type of mobile device you use including its make, model, operating software type and version and screen size, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), the type of mobile browser you use, time zone setting.
- Content Data, which includes information stored or located on your Device, including friends’ lists, login information, photos, videos or other digital content including information obtained from third party apps which you may use or have installed on your device, check-ins.
- Profile Data, which includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
- Usage Data, which includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Tracking Data, which includes tracking data related to your purchases and may include any website or other app which influenced your decision to obtain the App.
7. Special categories of personal data
Data protection law recognises that some categories of personal information are more sensitive, including information about a person’s health, race, ethnic origin, religious or political opinions, sex life, sexual orientation, trade union membership and genetic and biometric data.
We may collect data regarding your gender if you choose to use this functionality to receive personalised marketing information from us. We will only use gender data where you have expressly consented to us processing this information.
Once you provide consent, you may change your mind and withdraw consent at any time by emailing us at email@example.com or by deleting your data from the App at profile/your details/delete but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
8. How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, use any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Device Data from the following parties:
analytics providers such as Google based outside the EU;
advertising networks such as Reach PLC based inside the UK; and
search information providers such as Google.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Seopa Limited based inside the United Kingdom;
- Identity and Contact Data from data brokers or aggregators such as Experian based inside the UK as well as from social media channels including Instagram, Facebook and TikTok;
- Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK or the EU;
- Vehicle Data from the Driver and Vehicle Licensing Authority via data brokers such as Automotive Software Solutions Limited (ASSL) and EurotaxGlass’s both based in Switzerland;
- Driving Licence Data from the Driver and Vehicle Licensing Authority via data brokers such as Automotive Software Solutions Limited (ASSL);
- Device Data from the following parties:
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
10. How we use personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
11. Purposes for which we will use your personal data
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the App and register you as a new App user||Identity
|To process in-App purchases and deliver Services including managing payments and collecting money owed to us||Identity
Marketing and Communications Location
|Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)|
|To help you obtain vehicle finance when we may share your information with lenders and providers of hire purchase and similar financial services||Identity
All information listed above under “Insurance Data”
|Your consent Performance of a contract with you|
|To obtain insurance quotations for you when we will share information relating to you with insurers to obtain quotations for you:||Identity
Driving Licence Information
existing insurance details
no claims bonus details
details of any accidents in which you have been involved
details of driving related convictions and road traffic offences
|Your consent Performance of a contract with you|
|To store your information so you can easily access it||Vehicle Data including all items listed under “Vehicle Data” above. Driving Licence data including driving licence number, date of issue, time licence held, copy of driving licence Insurance Data including all items listed under “Insurance Data” above.||Your consent Performance of a contract with you.|
|To manage our relationship with you including notifying you of changes to the App or any Services||Identity
Marketing and Communications
|Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)|
|To enable you to complete a survey||Identity
Marketing and Communications
|Your consent Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)|
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||Identity
Device To deliver content and advertisements to you
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App||Identity
Marketing and Communications
|Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)|
12. Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the above table Purposes for which we will use your personal data:
- External Third Parties as set out in the [Glossary].
13. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
14. Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Your data is hosted on mirrored servers by Amazon Web Services, which is a market leading cloud services provider and cyber-protected by leading providers of cyber security services.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
15. Data retention
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after you cease being our customer for tax and regulatory purposes.
In some circumstances you can ask us to delete your data: see [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.
If you do not use the App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.
16. Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
- 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 where 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 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; or
- 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. However, 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.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
- Lawful Basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
2. Third Parties
3. External Third Parties
Amazon Web Services acting as processors for us and processing data for us in the United Kingdom and EU who provide data processing, IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.