1. Consent to installation of the CarCloud 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.

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
dataprotection@carcloudcommunity.co.uk
 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.

3. 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.

4. Who are we?

We are Pace Cloud Ltd trading as CarCloud and can be contacted on the below contact details:

• hello@carcloudcommunity.co.uk
• 0121 2328 628
• Pace Cloud Limited, Grosvenor House, 11 St. Pauls Square, Birmingham, B3 1RB

5. Our Data Protection Office:

Our data protection officer can be contacted on the below:

• Email: dataprotection@carcloudcommunity.co.uk
• Telephone: 0121 2328 628
• Post: Pace Cloud LimitedGrosvenor House, 11 St. Pauls Square, Birmingham, B3 1RB

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 www.carcloudcommunity.co.uk (Webapp Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device) or entered any information onto our site..

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.

6. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 8th March 2024. 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.

7. Why do we collect and use your personal information?

We collect and use your personal information in order to provide you with our service.

We use your personal information to send marketing communications to you about similar products and services that may be of interest to you. Depending on how you have advised you’d like to be contacted, we could send our marketing communications/updates to you by email, SMS and Push Notifications. It is to be noted that you can object to your personal information being used by us to send you marketing information and can make changes to your notification settings in ‘My Account’ page on the website (www.carcloudcommunity.co.uk) and via the app at anytime.

Each marketing/communication email and SMS will also include an unsubscribe link to enable you to opt-out of receiving future marketing communications.

8. What is our lawful basis for handling your personal information?

Under the General Data Protection Regulation (GDPR) we must have a lawful basis to legally handle your personal information. The lawful basis that we rely upon are as follows:

1. Contract – to take steps, at your request, to enter into a contract to fulfill your order and to perform our obligation under the contract (i.e., to deliver your order).  

2. Legal obligation – to share personal information with law enforcement agencies and regulatory bodies if required to do so by law.

3. Legitimate interests – to use your personal information to send you marketing communications about similar products/services in the future, to share your personal information with third party professional service providers that we engage, to administer prize draw competitions that you enter, and to share your personal information with our successor(s) in the event of a merger or acquisition.

4. Consent – to use the Experian partnership within our app and website, they require your consent to carry out a soft credit search to obtain the details required to offer their service. And consent to pass your data to MoneySuperMarket Group in order to provide you with a range of insurance quotes.

9. What happens if I do not provide my personal information?

We need your personal information in order to provide you with the use of our App and website and the products it contains to you. If we do not collect your personal information, we will not be able to provide our services to you.

10. Who will we share your personal information with?

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.

Car Insurance:  MoneySuperMarket Group

https://www.moneysupermarket.com/legal/privacy-policy/

(Please note that Moneysupermarket Group provide an url within our app and website to improve your customer journey and make the process as easy as possible, should you wish to enquire/apply with them for insurance products. We have included their Privacy Policy and details within this section so as to be fully transparent on who the insurance provider is within our app and website.)

Finance and Credit Services:  Experian

https://www.experian.co.uk/privacy/privacy-and-your-data?utm_medium=internalRef&utm_source=Consumer%20Services

Please note that Experian provides an iFrame within our app to improve your customer journey and make the process as easy as possible, should you wish to obtain information about any current finance that you have taken out on your vehicle. It could also assist in providing you options should you be looking to settle this finance or part exchange your vehicle to settle your finance. It will also provide you up to date information regarding your vehicle. We will not physically share your details with them, however depending on the information you have inputted within the app, it may pre populate some information for you to confirm. We have included their Privacy Policy and details within this section so as to be fully transparent on who the insurance provider is within our app.

In order to provide you with this service, Experian will carry out a soft credit search on your information. Please note if you proceed through them for a new finance product, the lender they pass your details onto may carry out a hard credit search that can impact your credit profile.

In order for you to use this service, we obtain your consent. Should you wish to withdraw this consent, we ask you to contact us using the contact details listed above. If you do not wish for a search to be carried out, we ask you not to use this service.

If you decide to proceed with any of the services Experian can offer, you will be directed to their website. We ask you to ensure you are aware how your information will be used, you consult their Privacy Policy notice.

The personal information we have collected from you may be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by our  partners and these fraud prevention agencies, can be found in the above privacy links.

If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs, and other organizations involved in crime and fraud prevention.

You can contact Credit Reference Agencies on the below:

Equifax Ltd, Customer Services Centre, PO Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or visit www.equifax.co.uk

Experian Ltd, The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham, NG80 1ZZ, UK https://www.experian.co.uk/contact-us/

Using Experian’s services, we also carry out a check on the vehicle registration you input into the app to determine if it has existing finance connected. This check will not provide us with any personal information, only if finance is present, when this started, the anticipated end date and the provider. No personal finance information is connected to this check, you have the option to enter the information into the app (such as monthly payment, settlement figure and balloon payment should you wish to. In order to use our app and services correctly, we ask you to enter as accurate information as possible to allow us to provide you with accurate example figures.

Marketing Partner:  Reach Publishing Services Limited

https://www.reachplc.com/site-services/privacy-policy

We may share your personal information with our marketing partner, Reach Publishing Services Limited.

11. Communications:

Twilio – https://www.twilio.com/legal/privacy

Iterable – https://iterable.com/trust/privacy-policy/

Where possible your data may be prepopulated if you decide to proceed with a third-party product presented in the app or website. We will always give you this option when proceeding. Please note, dependent upon the product, you may have to add in additional information in order to proceed.

We may share your personal information with law enforcement agencies, fraud prevention agencies and regulatory bodies such as the FCA and HMRC when required to do so by law.

Microsoft Azure Web Services  – Acting as processors for us and processing data for us in the United Kingdom and EU who provide data processing, IT, security and system administration services.

Amazon Web Services – Acting as processors for us and processing data for us in the United Kingdom and EU who provide data processing services.

Iterable – We use Iterable for our CRM and Marketing platform. You can find further information on how they process and store your information here Iterable Privacy Policy – Iterable

We may engage the services of professional advisers such as compliance consultants, lawyers and accountants who may be given access to your personal information in order to provide their services to us. We will ensure that your personal information is protected by obtaining a written undertaking of confidentiality from the professional service providers.

In the event we are subject to a merger or acquisition we may share your personal information with the organisation(s) that acquire or merge with our business and/or their professional advisers in the course of the acquisition or merger transaction and thereafter. In such circumstances the latter organisation will be required to use your personal information in the same ways described in this privacy policy.  

12. How long will we store your personal information?

We will store your personal information for up to six years from ceasing to be our client. This is to enable us to refer to our records in the unlikely event that you want to lodge a complaint against us within six years.  Please note if we require your information for accounting purposes, it will be kept for 7 years.

If you do not exercise your right to object to marketing or unsubscribe to our marketing emails, we will store your personal information for marketing purposes until you exercise your right to object or unsubscribe. Please note cookie and analytical information is kept for 14 months.

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.

13. What are your rights in relation to your personal information?

Right to access: You have the right to request copies of the personal information we hold about you at any time.

Right to rectification: You have the right to request that we correct any inaccurate personal information we hold about you.

Right to erasure: You have the right to request that we delete your personal information from our records.

Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

Right to restrict processing: You have the right to request that we restrict how we use your personal information.

Right to object: You have the right to object to the collection and use of your personal information at any time.

Right to data portability: You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.

Right to withdraw consent: You have the right to withdraw your consent for us to use your personal information at any time.

14. How can I exercise my rights in relation to my personal information?

You can exercise all your rights by contacting us on any of the above contact details. Please note that as a regulated firm, in addition to GDPR and Data Protection Laws, we are also required to abide by other regulations and laws.

Due to this, we may not be able to fully act on your requests; however where these exemptions apply, our team will fully explain why we are limited to act on your request, or how we have partially acted on your request.

You can lodge a complaint with us directly by contacting us on one of the above contact details.

You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO). The ICO is the regulator who makes sure that we use your personal information in a lawful way.

You can lodge a complaint with the ICO by following this link https://ico.org.uk/concerns/ or calling the ICO on 0303 123 1113.

15. 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 residential address, billing address, delivery address, email address, and telephone numbers.

Driving Licence Data: your driving license number and the length of time you have held a driving license as well as a copy of your photocard driving license.

Vehicle Data, which includes details of your current and previous vehicles namely make, model, description, registration number, mileage, valuation details (current and future forecast), estimated future cost of ownership, MOT status and renewal dates, road tax licencing status and renewal dates and cost and SORN status, 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, manufacturer warranty details, date of last keeper change and number of previous keepers, and CO2 emissions.

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 offenses 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, and premium quotations.

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.

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 App 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.

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: dataprotection@carcloudcommunity.co.uk or by deleting your data from the App or website at profile/your details/delete but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

16. 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 collect about you and your device. Each time you visit one of our sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details. Information you enter into our website.

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: Experian Limited, MoneySuperMarket Group, Seopa Ltd and Reach Publishing Services Limited.

Device Data from the following parties:

analytics providers such as Google based in and outside the EU;

advertising networks such as Reach Publishing Services Limited 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 and Seopa 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);

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.

17. Cookies

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

18. How we use your 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

and lawful basis:

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.

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. Purposes for which we will use your personal data

19. 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:

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 policy.

We do not transfer your personal data outside the European Economic Area (EEA).

20. 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

Azure Web Services via a MySQL database, which is a market leading cloud services provider and cyber-protected by leading providers of cyber security services.

Amazon Web Services via storage containers, 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.

Glossary

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.