Privacy & Cookie Policy
Privacy Policy updated on 25/03/2022
This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our web sites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
General Information
What is personal data?
Personal Data is information by which you can be directly or indirectly identified (“Personal Data”). This generally includes information such as your name, address, email address and telephone number; however, it may also include other information such as your IP address, shopping habits, lifestyle habits or preferences such as interests.
What is processing?
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
What is the applicable data protection law?
As a UK based Company we are bound to follow the UK’s Data Protection Act (“DPA”). Since we are however a company that operates globally we have also adopted the principles set out in the EU’s General Data Protection Regulation (“GDPR”). Given the similarity of both provisions no conflict should arise, but if it does we will follow the most stringent provision in order to ensure the highest data protection standard available.
Who is the supervisory authority?
The Information Commissioner’s Office (ICO) provides advice and information for individuals about protecting personal information. They also enforce national privacy laws and are the for us relevant data protection authority. You can find the ICO’s contact details on their website at www.ico.org.uk.
Who is the responsible for processing personal data?
The responsible party within the meaning of the DPA and the GDPR is:
Rated Driving Instructors Ltd
The Carriage House,
Mill Street,
Maidstone,
Kent,
United Kingdom,
ME15 6YE
(hereinafter referred to as “we”, “us” or “our”)
What are the legal bases of processing personal data?
The legal bases for processing are listed below and at least one of these must apply whenever we process personal data:
a) Consent: the individual has given clear consent to process personal data for a specific purpose.
b) Contract: the processing is necessary for a contract or because you have asked us to take specific steps before entering into a contract.
c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
d) Vital interests: the processing is necessary to protect someone’s life.
e) Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.
What are your rights?
You have the following rights with respect to us processing your personal data:
Right of access
You have the right to obtain information about whether and which of your personal data is processed by us. In this case, we will also inform you about:
- the purpose of processing;
- the categories of data;
- the recipients of your personal data;
- the planned storage period or the criteria for the planned storage period;
- Your further rights;
Unless we have been provided with your personal data by you: Any available information about its origin
if available: the existence of automated decision-making and information about the logic involved, the scope and the intended effects of the processing.
Right to rectification
You have a right to rectification and/or completion if your personal data processed by us is inaccurate or incomplete.
Right to restriction of processing
You have a right to restriction of processing, provided that
- we verify the accuracy of your personal data processed by us;
- the processing of your personal data is unlawful;
- you need your personal data processed by us for legal prosecution after the purpose has ceased to exist;
- you have objected to the processing of your personal data and we are reviewing this objection.
Right to erasure
You have a right to erasure if
we no longer need your personal data for its original purpose;
- You withdraw your consent and there is no further legal basis for processing your personal data;
- you object to the processing of your personal data and – unless it is direct marketing – there are no overriding reasons for further processing;
- the processing of your personal data is unlawful;
- the erasure of your personal data is required by law;
- your personal data was collected as a minor for information society services.
Right to information
If you have exercised your right to rectification, erasure or restriction of processing, we will inform all recipients of your personal data, of this rectification, erasure of data or restriction of processing.
Right to data portability
You have a right to receive your personal data processed by us on the basis of consent or for the performance of a contract in a structured, common and machine-readable format and to transfer it to another controller. If technically feasible, you have the right to have us transfer this data directly to another controller.
Right to object
You have the right to object to the processing of your personal data in case of special reasons. In this case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing. In case of processing of your personal data for direct marketing purposes, you have the right to object at any time.
Right of withdrawal
You have the right to revoke any consent given to us at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data by us violates the law.
Data processing on our website
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/
The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
Provision of the website and creation of log files
The legal basis for the processing of your personal data in the context of the provision of the website and the creation of log files is our legitimate interest. The temporary storage of your personal data by us is necessary to enable delivery of the website to your computer or device.
For this purpose, your personal data must be stored for the duration of the session. The storage of your personal data in log files is done to ensure the functionality of the website. In addition, we use your personal data to optimise the website and to ensure the security of our information technology systems. Your personal data is not processed in any other way.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of your personal data for the provision of the website, this is given as soon as you have left the website.
In the case of storage of your personal data in log files, these are deleted after 7 days at the latest. If the data is stored beyond this period, your personal data will be anonymised so that it can no longer be assigned.
The collection of your personal data for the provision of the website and the storage of your personal data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for you to object.
Use of technically necessary cookies
The legal basis for the processing of your personal data in the context of the use of technically necessary cookies is our legitimate interest. The use of technically necessary cookies serves to simplify the use of our website for you.
Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that your internet browser is recognised even after a page change. Your personal data will not be processed in any other way.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected; this is particularly the case when you leave the website.
Cookies are stored on your computer or device in the case of permission and are transmitted from this to our website. Therefore, you have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies.
You can delete cookies that have already been stored at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
To learn more about cookies please visit All About Cookies and to learn more about the cookies we use please refer to our Cookie Policy.
Customer account registration
The legal basis for the processing of your personal data in the context of customer account registration is the performance of a contract. Your registration enables in particular the conclusion of contracts as well as the maintenance of our customer relationship.
We collect data when you create or update your account and this may include your name, email, phone number, login name and password, address, profile picture, payment or banking information, travel information.
The processing of your personal data within the scope of registration is therefore necessary for the fulfilment of a contract or the implementation of pre-contractual measures as well as the successful maintenance of our customer relationship.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case at the latest in the event of the termination of your customer account.
You have the option to cancel your customer account registration at any time. In this case, your personal data will be deleted unless legal retention periods prevent deletion.
Newsletter and pre-alerts
The legal basis for the processing of your personal data in the context of sending the newsletter and pre-alerts is your consent. The purpose of collecting your personal data is to send the newsletter and pre-alerts to you.
The purpose of processing your personal data in the context of sending the newsletter and pre-alerts is to send you information, offers and, if applicable, to promote sales.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. Accordingly, your personal data will be stored until you have unsubscribed from our newsletter and pre-alerts.
You can revoke your consent to receive the newsletter and pre-alerts at any time or use the unsubscribe link contained in each newsletter and pre-alert to object to further receipt of the newsletter and pre-alerts.
Contact form, feedback form, e-mail and social media contact
The legal basis for the processing of your personal data transmitted in the course of you contacting us is our legitimate interest. If the contact aims at the conclusion of a contract, the performance of a contract is an additional legal basis for the processing of your personal data. The processing of your personal data in the event of a contact serves us solely to process your request.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case for the personal data sent in the course of contacting us when your request has been processed and legal retention periods do not prevent deletion.
You have the option at any time to object to the processing of your personal data in the context of contacting us for the future. In this case, however, we will not be able to process your request any further.
All personal data stored in the course of contacting you will be deleted in this case, unless legal retention periods prevent deletion.
Communication with other users
We store and process our users’ communications for both chat and in app calls, as well as communications with customer service for security and quality control measures.
The legal basis for the processing is our legitimate interest in the security, to investigate and to resolve complaints and to ensure quality control of our services.
The recordings will be stored on a secure server which will only be accessible by senior members of our management team. We may share recordings with an Investigating Officer or law enforcement in order for them to respond to a complaint or issue.
Direct marketing
The legal basis for the processing of your personal data in the context of direct marketing measures is either your consent or our legitimate interest in marketing and promoting our courses and services.
The purpose of processing your personal data in the context of direct marketing measures is to send information, offers and, if applicable, to promote sales.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected; this is the case in particular upon receipt of the revocation or objection.
You can revoke your consent at any time for the future or object to the processing of your personal data in the context of direct marketing measures at any time for the future.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation.
The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process.
You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future.
In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defence and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defence and enforcement of our rights is our legitimate interest. The purpose of processing your personal data in the context of legal defence and enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of claims and rights.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The processing of your personal data in the context of legal defence and enforcement is mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to object.
Our Third Party Providers
Google reCAPTCHA
On this website we use the reCAPTCHA function of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This function is primarily used to distinguish whether an entry is made by a natural person or by a machine and/or automated processing.
The service involves sending the IP address and, where applicable, other data required by Google for the reCAPTCHA service to Google and is carried out on the basis of our legitimate interest in determining individual personal responsibility on the Internet and preventing abuse and spam.
The use of Google reCAPTCHA may also involve the transmission of personal data to the servers of Google LLC. in the USA.
Google Maps
On our website we use Google Maps (API) from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information.
When you call up those pages in which the Google Maps map is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers and stored there; this may also involve transmission to the servers of Google LLC. in the USA.
This occurs regardless of whether Google provides a user account via which you are logged in or whether a user account exists. If you are logged in to Google, your data will be directly assigned to your account.
If you do not wish to have your data associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them.
The collection, storage and evaluation are carried out on the basis of Google’s legitimate interest. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.
If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser.
Google Maps and thus also the map display on this website can then not be used.
Google Analytics
This website uses Google Analytics, the web analytics service provided by Google. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site.
The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymisation is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing us with other services relating to website activity and internet usage.
The IP address transmitted by your internet browser as part of Google Analytics will not be merged with any other data held by Google.
The legal basis for the processing of your personal data is our legitimate interest. The processing of your personal data enables us to analyse your usage behaviour.
By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness.
By anonymising your IP address, your interest in the protection of personal data is sufficiently taken into account.
Your personal data will be deleted as soon as it is no longer required for our aforementioned purposes.
If you do not want your data to be collected by Google Analytics, you can install this browser add-on to disable Google Analytics. This add-on instructs Google Analytics JavaScript running on websites not to allow information to be sent to Google Analytics. For detailed information on installing and uninstalling the add-on, see the relevant help resources for your Internet browser.
Facebook Pixel
In addition to Google Analytics, we also use the Facebook Pixel web tracking and web analysis tool.
The legal basis for the processing of your personal data is our legitimate interest. The processing of your personal data enables us to analyse your usage behaviour.
Based on the data obtained, we are able to compile information about the use of the individual areas of our website. This helps us to continuously improve our website and its user-friendliness. Your personal data will be deleted as soon as it is no longer required for our previously named purposes.
Cookies are stored on your computer and transmitted from it to our website. Therefore, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies.
You can delete cookies that have already been stored at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
Your personal data collected in the course of using Facebook Pixel is provided to us by Facebook. If you do not want your data to be collected by Facebook, you have the option at any time to object to the processing of your personal data within the scope of Facebook Pixel for the future. In this case, we will forward your objection request to Facebook.
Online presences in social media
We maintain online presences within social networks and platforms (Instagram, Facebook, Twitter) in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there.
When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.
Hosting
The services for hosting and displaying the website are partly provided by our service provider as part of processing on our behalf. Unless otherwise explained in this privacy policy, all access data and all data collected in forms provided for this purpose on this website are processed on their servers.
If you have any questions about our service providers and the basis of our relationship with them, please contact us.
Content Delivery Network
For the purpose of a shorter loading time, we use a so-called Content Delivery Network (“CDN”) for some offers. With this service, content, e.g. large media files, are delivered via regionally distributed servers of external CDN service providers.
Therefore, access data is processed on the servers of the service providers. Our service providers work for us within the framework of order processing. If you have any questions about our service providers and the basis of our cooperation with them, please contact us.
How we process your information
We may process the data we collect for the following purposes and legal bases:
To provide our services and to fulfil contractual obligations:
- To carry out contracts with you such as fulfilling our obligations and processing payments for our services and dealing with your enquiries;
- to communicate with you about your enquiries, questions and comments; and to provide online services to you;
Legitimate interests we have as a business:
- Direct marketing and other forms of marketing such as in cases when we inform you about our products and services, competitions, offers or promotions that we think may interest you;
- when we identify you in order to improve or personalise your user experience on our online services;
- To manage our business and develop our services and products, such as conducting customer and market research, feedback surveys and statistical/demographic surveys, and evaluating the effectiveness of our sales, organisation/services and marketing;
- Maintain, manage and optimise our products, offerings, promotions, online services and other technologies and diagnose technical and service issues;
- Ensuring and evaluating the security and stability of our networks and systems and identifying a fraud prevention device; and To establish, exercise or defend legal rights.
To comply with legal obligations:
- Protecting, detecting and preventing fraud and other crimes, claims and other liabilities;
- To comply with legal obligations and our policies;
Monitoring and reporting compliance issues; and - Complying with court and regulatory orders.
With your consent (where required by law), we may use the information we collect for the following purposes:
- to send you emails or messages about our products and services, competitions, offers or promotions that we think may interest you;
- to send you emails or messages about our business partners’ products and services;
- To provide location-based services;
- Installing cookies and similar technologies; and
- Providing online services to you, including our web sites or mobile apps.
We may process the data we collect about you in other ways that we will inform you about at the time of collection or for which we will seek your consent.
How we share the data we collect
We do not sell your personal data and will only share your data as described in this privacy policy.
We may share your personal information with service providers who perform services for us, providing data processing and other IT services, administering promotions, contests and sweepstakes, conducting research and analysis, and for targeted information and advice about products and services.
We do not permit these service providers to use this data for their own purposes or to use it for any purpose other than to provide services on our behalf.
For strategic or other business reasons, we may decide to sell or transfer all or part of our business. As part of that sale or transfer, we may share data that we have collected and stored, including personal data, with anyone involved in the sale or transfer.
We may share data if it does not uniquely identify you. For example, we may share anonymous aggregate statistics about your use of our online services. Or we may combine data about you with that of other guests and share the data in ways that cannot be attributed to a specifically affected guest.
We may use or disclose personal information when necessary to comply with laws, regulations or legal requirements; to protect our online services and restaurant technology; to assert or defend legal claims; to protect the rights, interests, safety and security of our organisation, our employees or franchisees, or the public; or in connection with the investigation of fraud or other crimes or violations of our internal policies.
Miscellaneous and closing
Transfer of personal data to a third country
In the course of processing your personal data, we may transfer your personal data to trusted and specially selected service providers in third countries. Third countries are countries that are outside Scotland or the European Economic Area.
In doing so, we only work with service providers who can provide us with suitable guarantees for the security of your personal data and guarantee that your personal data will be processed in accordance with strict data protection standards. In the present case, it is not excluded that we transfer data to service providers in the USA.
Online Payment, Secure data transmission and Credit card information
The transmission of your personal information during an order transaction is encrypted using industry standard Secure Socket Layer (“SSL”) technology, (SSL encryption version 3).
Any credit card information you provide will not be stored by us, but will be encrypted and collected directly from our payment service provider (Stripe) via hypertext transfer protocol secure (“https”).
We may share information with our payment service provider, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorise payment following a secure link.
The information which you supply to in such cases is not within our control and is subject to our payment service provider’s own Privacy Policy and Terms and Conditions.
Security measures
For security reasons and to protect the transmission of content, that you send to us, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case, the provision of certain personal data may be necessary for the provision of the above services. If you do not provide us with this personal data, we may not be able to provide the service.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Do Not Track
Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.
Do Not Sell My Personal Information
We do not sell information that directly identifies you, like your name, address or phone records.
Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Children Data
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.
Changes
This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes.
Queries and Complaints
If you have any questions, please do not hesitate to contact us at support@rateddriving.com
