Specialised Hire Solutions

Privacy policy – GDPR Compliant 1.1

Publication date: 10/04/2018

  1. Introduction

1.1    We are committed to safeguarding the privacy of clients, hirers & partners; in this policy we explain how we will handle your personal data.

1.2    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

  1. Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process your account data (“account data“). The account data will include your name, address, telephone number, date of birth, occupation, email address, and driving license conditions. The source of the account data is you, your employer (if you work for an operator) or a booking agent (if a vehicle is booked via a third party and you consent to your data being shared via their own protocols). The account data may be processed for providing our services, complying with licensing laws, maintaining back-ups of our databases, for vehicle insurance purposes and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business & the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and/or to cater for the conditions of a contract between yourselves, us and a third party booking platform if applicable

3.3    We may process your personal data that we are provided during the use of our services. (“service data“). The service data may include name, address, telephone number, date of birth, occupation, email address, and driving license conditions. The source of the service data is you or your employer (if you work for an operator) or a booking agent (if a vehicle is booked via a third party and you consent to your data being shared via their own protocols). Bookings made via a third party are known as “third party processors” The service data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases, complying with licensing laws, for vehicle insurance purposes and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and/or to cater for the conditions of a contract between yourselves, us and a third party booking platform if applicable.

3.4    We may process information that you post for publication on our website, social media sites (third party processors) or through our services. (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business. Prior to publishing a review on our site, we will request your consent to do so. If you choose to post a review or question on social media platforms or review sites (third party processors), then this is done so with the adherence and acknowledgement to the privacy policy of that third-party processor. If we publish a review from someone on our website, we will only publish their name and comments.

3.5    We may process information contained in any enquiry you submit to us regarding vehicle hire services. (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. Specifically, upon the website: www.shshire.com the enquiry data we process is via:
Contact form – (name, email address and telephone number(optional)). This data is processed for the purposes of customer support/relations, enquiries, sales and marketing. The legal basis for this processing is consent.
Vehicle enquiry form – (name, email address and telephone number (optional)). This data is processed for the purposes of sales and marketing. The legal basis for this processing is consent.

3.6    We may process information relating to transactions, including purchases of goods and services, that you enter with us. (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.

3.7    We may process information that you provide to us for subscribing to our newsletters. (“notification data“). The notification data may be processed for the purposes of sending you the relevant newsletters/marketing. The legal basis for this processing is consent. You can unsubscribe from these emails at any time by clicking the “unsubscribe” link at the bottom of the email and this will remove you from the list. SHS Hire uses the company “Mailchimp” for its newsletter function. Mailchimp is a third-party processor and the data that a user inputs to subscribe is stored on secure servers belonging to Mailchimp and not that of SHS Hire. Prior to subscribing to newsletters from SHS Hire, we encourage for you to view the privacy policy and GDPR terms of Mailchimp.

3.8    We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Complaint form – (name, email address and telephone number(optional)). This data is processed for the purposes of business operations and customer support/relations. The legal basis for this processing is consent.
Contact form – (see 3.5)

3.9    We may process information attained from your use of our fleet with onboard trackers & dashboard cameras (dash cams -outwards facing only). (“Locational data”). This locational data may include the vehicle’s trips, usage and driving patterns which reflect your location and driving style.
The locational data may be processed for the purposes of managing risk to our assets and/or for the proper administration of the conditions of a hire. We may share information from these systems with an insurer or accident management company, or referral agents for the purposes of risk management. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.10  We may process data about your use of our website and services (“usage data“). The usage data may include your, referral source, length of visit, page views and website navigation paths. Although this will not identify you, only a device that you use to access our website. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.11  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.13  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

3.14  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1    Specialised Hire Solutions trades from one location only and your personal information will be made available to all departments within this company for the purposes of all reasonable business operation.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    We may disclose your personal contact details to our suppliers or subcontractors insofar as reasonably necessary for making appointments such as fitting cameras, trackers, and vehicle servicing. Prior to this, however, we will seek your consent.

4.4    Financial transactions relating to our services are handled by our payment services providers, Barclays Bank PLC. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.barclays.co.uk/journal/gdpr/.

4.5    In the unlikely event that financiers take over the management of our account customers, then we are duty bound to share account data with these is so far as is necessary for them to manage and control the financial operations of the business.

4.6    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

  1. International transfers of your personal data

5.1    Specialised Hire Solutions is a UK based company with no offices or business outside of jurisdiction of the United Kingdom.

5.2    Our website is hosted in the United Kingdom as is our client database system, therefore personal details will not be transferred to other countries for business purposes without an amendment of this policy and prior notification.

5.3    Should personal data be requested by a law enforcement agency based outside of the United Kingdom, then UK based compliance protocols will need to be met before any information is released.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)    Account data, Service data & correspondence data, will be retained for a minimum period of 4 years following the end of your last hire, and for a maximum period of 6 years following the end of your last hire.

(b)    Usage data will be retained for a minimum period of 6 months and for a maximum of 2 years following the introduction of GDPR on 25 May 2018.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of publication, enquiry and notification data will be determined based on when consent is withdrawn to which, no further communication will be made, however, details will be retained for a maximum period of 6 months from this point. If this data relates to usage of social media or other third party processors, then that platform’s retention policies will apply and by using social media to communicate with us, you acknowledge that specific platform’s policies.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

  1. Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email.

  1. Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

  1. Our details

9.1    Our website is owned and operated by Digital Pie. As the website managers, they will be able to view any information processed or transferred through the site, however, the website does not store data itself.

9.2    We are registered in England and Wales under registration number 8170718, and our registered office is at Unit 6 Buckingham Court, Rectory Lane, Loughton, Essex, IG10 2QZ.

9.3    Our principal place of business is at Unit 5 Rear of 76 Station Way, Buckhurst Hill, Essex, IG9 6LL

9.4    You can contact us:

(a)    by post, to the postal address given above

(b)    using our website contact form; www.shshire.com

(c)    by telephone, on the contact number published on our website or

(d)    by email, using the email address published on our website