1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“We/Us/Our” Means WheelClick Ltd, a limited company registered in England, no. 9527114, whose registered address is 71-75 Shelton Street, London, WC2H 9JQ. We are registered with the ICO under reference ZA714356.
“Our Services” means Our websites, applications, mobile refuelling service offering and any other service We provide.
We understand that your privacy is important to you and that you care about how your information is used and shared. We respect and value the privacy of everyone who uses our services and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
3. Information About Us
The data controller for our sites and applications is WheelClick Ltd, a limited company registered in England, no. 9527114, whose registered address is 71-75 Shelton Street, London, WC2H 9JQ. Our ICO registration is ZA714356.
4. Scope – What Does This Policy Cover?
5. What Data Do We Collect?
Some data will be collected automatically by Our Services. Other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 6, for example when using our website contact form.
Depending upon your use of Our Services, We may collect some or all of the following data:
- 5.1 Name;
- 5.2 Business and/or company name;
- 5.3 Contact information such as email addresses and telephone numbers;
- 5.4 Address and location data;
- 5.5 IP address;
- 5.6 Web browser type and version;
- 5.7 Operating system;
- 5.8 A list of URLs starting with a referring website, your activity on our websites, and the web site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation.
6.2 We use your data to provide the best possible services to you. This includes:
- 6.2.1 Providing and managing your access to Our Services;
- 6.2.2 Personalising and tailoring your experience on Our Services;
- 6.2.3 Supplying Our Services to you;
- 6.2.4 Personalising and tailoring Our Services for you;
- 6.2.5 Responding to communications from you;
- 6.2.6 Supplying you with email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by contacting us or using an unsubscribe link)
- 6.2.7 Market research;
- 6.2.8 Analysing your use of Our Services to enable Us to continually improve them and your user experience;
6.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
6.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, or text message with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications Regulations.
6.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
7. How and Where Do We Store Your Data?
7.1 We only keep your data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
7.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties, and using third parties which adhere to the EU-US and Swiss-US Privacy Shield Frameworks.
7.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. We will manage your data according to our IT Security Policy and industry standard security methods.
7.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
8. Do We Share Your Data?
8.1 We may contract with third parties to provide services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, and advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 We may compile statistics about the use of Our Services including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
8.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
9. What Happens If Our Business Changes Ownership?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 When you submit information via Our Services, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.)
10.2 You may also wish to sign up to one or more of the preference services operating in the United Kingdom: 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.
11. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
11.1 You may access some of Our Services without providing any data at all.
11.3 You may withdraw your consent for Us to use your personal data as set out in section in 6 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
12. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 16.
13. No Users Under 17 Years of Age
Our Site and Our Services are not intended for use by anyone under the age of 17, and WheelClick Ltd does not knowingly collect or solicit personal information from anyone under the age of 17. If you are under 17, you may not send any personal data about yourself to us, including, but not limited to, your name, address, telephone number, email address, or any other details. If we have unknowingly collected personal information from someone under the age of 17, upon verification from a parent or legal guardian we will delete those records from Our system. If you are a parent or legal guardian of someone under 17 and believe that we might have any information from or about such person, please contact us using the details provided in section 15.
14. Summary of Your Rights under GDPR
Under the GDPR, you have:
- a) the right to request access to, deletion of or correction of, your personal data held by Us;
- b) the right to complain to a supervisory authority;
- c) the right to be informed of what data processing is taking place;
- d) the right to restrict processing;
- e) the right to data portability;
- f) the right to object to processing of your personal data;
- g) rights with respect to automated decision-making and profiling.
15. Automated Decision-Making and Profiling
15.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
15.2 The right described in section 14.1 does not apply in the following circumstances:
- a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
- b) The decision is authorised by law; or
- c) You have given you explicit consent.
15.3 Where We use your personal data for profiling purposes, the following shall apply:
- a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- b) Appropriate mathematical or statistical procedures will be used;
- c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
16. Contacting Us
If you have any concerns about the use of your data or wish to make a complaint, you may contact us in the first instance using the contact details provided in section 16. Alternatively, you may contact the UK supervisory body, the ICO, at https://ico.org.uk/make-a-complaint/.