This policy explains how Passo Digital Limited collects and processes information about you which is personally identifiable ("Your Information") when you use the Passo app or website ("Passo"), whether you are a driving instructor, learner driver or visitor.Passodigital.co.uk and Passo App (together “Passo”) (referred to as “us”, “we”, “our” and ‘Passo” as contextually required) are provided by Passo Digital Limited, company number10755559 , registered at 1 Fore Street Suite 6086, Moorgate, London, England, EC2Y 9DTIf you have any queries about how we use Your Information or have a complaint, please contact us at firstname.lastname@example.org
At Passo Digital, we are committed to maintaining the trust and confidence of our website and app visitors, learners and instructors. We want to make it very clear that Passo Digital is not in the business of renting or trading emails lists with other companies and businesses for marketing purposes. We do list publicly available information of Driving instructor but do not provide this information to any third party for marketing purpose.
1. Your Rights
You have certain rights in relation to your personal data, which we have outlined below. Under certain circumstances, by law you have the right to:
· Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.
If you want to exercise any of these rights, then please contact us using the details above. The various rights are not absolute, and each is subject to certain exceptions or qualifications. We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
Inform us about your data changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Fees to access data
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.
Right to Complain
If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, contact us email@example.com. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law. If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
2. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
3. Data Categories we collect
In addition to using cookies on our website, we may collect and process the following information from you when you fill in a form on our website or have contact with us by letter, email, telephone or other means.
Basic personal details including your full name and address (and proof of name and address), email address, telephone number, any other contact details you supply, driving licence image, number, date of birth and Banking details.
We may use data taken from your mobile sensor, location data, including your journey start and end points, route taken, average speed, lane change and use Records of all communications including recordings of phone calls and electronic communications with our staff.
Listed Driving Instructors:
Basic personal details including your full name and address (and proof of name and address), email address, telephone number, any other contact details you supply, ADI Badge, driving licence number, vehicle make, Banking details and date of birth. Data from your mobile sensor such as ratings information, location data, including your journey start and end points, route taken and average speed. Records of all communications including recordings of phone calls and electronic communications with our staff and to the learner through our app.
We may also receive information about you from third parties such as Facebook, Twitter and our insurance partners. Basic personal details including your full name, address, email address, telephone number and other contact details. Data received from background checks related to the partner driving instructor application process. This may include criminal record checks and credit history, or bankruptcy checks as required for regulatory purposes.
Information from your use of our website
We use your data for the purposes- to enable the provision of the products and services you have requested. To deliver service information about the products and services you have purchased. To contact you for your views on our products and services;
4. Use of the information we collect
The information which we collect and what we use it for will depend on the nature of our business relationship with you. We use your information. To provide you with services which you have requested and to fulfil our contractual obligations towards you. To provide learner information to instructors to allow them to accept and schedule a lesson with the learner and for ongoing communications purposes. For our own internal record keeping, including determining eligibility for pricing offers. To improve our products and services. To customise the Passo website and apps according to your interests. To governmental, regulatory or law enforcement agency requests. Other purposes which are advised at the point of collection, and in compliance with our Data Controller registration with the Information Commissioner's Office.
5. Information for marketing purposes
We use your information to identify products and special offers that we think may be of interest to you. We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you. You have the right to ask us not to not send you marketing messages by post or e-mail or any combination of these at any time.
You can do this- in case you wish to withdraw from all marketing communications, you can unsubscribe from all marketing by clicking the appropriate link in - any email you receive; or by logging into app/dashboard and changing your preferences; or at any time by contacting us (see above).
If you choose to unsubscribe, we will cease to send you such communications as mentioned above.
6. Why we are collecting and using the information
We are entitled to use your personal data in the ways set out in this policy on the following bases:
the use of personal data in this way is necessary for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract. we have legal obligations that we have to discharge- the use of your personal data is necessary for our legitimate interests in ensuring the quality of the products and services we provide to you. Determining eligibility introductory pricing and other offers. Collecting information for marketing purposes and statistical analysis.
you have consented to such use;
to establish, exercise or defend our legal rights for the purposes of legal proceedings. If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to provide certain products or services to you. If you do choose to provide your consent you can withdraw it at any time by contacting us (see above).
7. Third Party Providers
Passo Digital will act as a Joint Controller with our Listed Driving Instructors relating to the exchange of personal learner data to carry out our contractual obligations. This information will be transmitted securely via our app.
Where necessary, we may share your personal data with the following third parties:
· Software providers;
· Web analytics providers;
· Cloud computing providers;
· Payment processing and accounting providers;
· Email providers;
· Telephone providers;
· Marketing providers;
· Social media providers;
· Law enforcement agencies and regulators, government departments or competent authorities of the UK or of other countries; and
If you have consented to any disclosure to a third party.
8. Where we store your information
We transfer, use and/or store your personal information inside of the European Economic Area (“EEA”) and the laws of these destination countries offer the standard of protection for personal information. We may update this list from time to time and any changes will be communicated to you via an update to this Privacy Notice. Transfers to our third-party service providers are to enable them to use and store your personal information on our behalf. We will, however, put in place appropriate security procedures to protect your personal information. We also ensure that, where your information is transferred to any country outside the EEA this is done using specific legally-approved safeguards. You can request further details and a copy of these by contacting us.
We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by encrypting our outgoing email communications, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You should be aware that this may prevent you from taking full advantage of the Passo website. If you are unsure how to do this, use your favorite search engine to look this up using the term 'declining cookies' with your browser name.
11. Google Analytics
Google Analytics uses traffic log cookies to gain information about the use that is made of pages on our website. We use the information from cookies to generate reports on the usage of our website which are used for evaluation and analysis. The purpose is to improve our website by tailoring it to the needs of users. No data specific to any identifiable user is retained.
As a user you can opt out of this process of collecting traffic log data. To do so please visit the following site which provides a browser add-on that enables a user to opt out - http://tools.google.com/dlpage/gaoptout.
12. Changes to our Privacy Notice