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How’s My Driving Limited 03079986 (hereby referred to interchangeably as HMD) is part of the How’s My Limited Group. HMD is an intermediary company in the business of supporting the management of occupational road risk for fleet vehicles by receiving incident reports on behalf of those companies and processing the incidents to a successful conclusion.

We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. “Personal Information” is information that identifies you as an individual such as your name, date of birth, email address, IP address and CV.

Last Updated April 2018

How do we collect data about you?

We collect and use your Personal Information in accordance with this our Privacy Policy.

The majority of the Personal Information you provide to us freely when you contact us to report an incident or when you approach us to provide information or quotation about our service.

If you do not wish for the HMD to hold or collect data about you – please do not submit information to us.

We also collect from:

  • our websites (the “Websites”);
  • the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
  • cookies (“Cookies”);
  • publically available information; and
  • other tools and applications (our “Online Content”).

What Personal Information do we collect?

Personal Information we collect about you may include the following:
  • General identification and contact information: your name; address; email; IP address; telephone details; gender; and in the case of some companies, photographs and videos
  • Information enabling us to provide products and services: location, name and contact details
  • Marketing preferences: enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey
  • Statistical information: incident type and number
  • Information from Apps: submit comments to the Site, participate in message boards, blogs, send us emails or any other user generated content facility
  • Publically available information in relation to professional history: educational background; employment history; skills and experience; professional licenses and affiliations; educational and professional qualifications

What legal basis do we rely on to process your Personal Information?

Consent

HMD on some occasions may process your data with your consent. For example, we rely on consent when we send promotional material or when you link your HMD account to your Social Network account. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. The processing is necessary to fulfil a contract HMD may process your data when we need to do this to fulfil a contract with you, such as to send your incident report or provide feedback to that report; process badge orders and queries.

Legitimate Interest

HMD also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. Our legitimate interests include:
  • ensuring the security and integrity of our Services and in ensuring that our Websites and Apps operate effectively;
  • selling and supplying goods and services to our customers;
  • protecting customers, employees and other individuals and maintaining their safety, health and welfare;
  • promoting, marketing and advertising our products and services;
  • sending promotional communications which are relevant and tailored to individual customers;
  • understanding our customers’ behaviour, activities, preferences, and needs;
  • improving existing products and services and developing new products and services;
  • handling customer contacts, queries, complaints or disputes; and
  • fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
  • The processing is necessary because of a legal obligation that applies
HMD may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies

Who do we share your Personal Information with?

HMD may make Personal Information available to:

Our group companies

We are a member company of How’s My Ltd. We may share your personal data with certain members of our group companies, but only for the purposes set out in this Privacy Policy and we remain responsible for the management and security of jointly used Personal Information. Access to Personal Information within HMD, and our group of companies, is restricted to those individuals who have a need to access the information for our business purposes.

Our service providers

This includes external third-party service providers, such as our call centre, accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

Governmental authorities and third parties involved in court action

HMD may share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

Other third parties

Occasionally, we may share Personal Information with other third parties. We will always do this under contract and in accordance with your instructions.

How we use Personal Information?

We use Personal Information to do some or all of the following:
  • Communicate with you as part of our business;
  • Send you important information regarding changes to our policies, other terms and conditions, the HMD Website and other administrative information;
  • Provide improved quality, training and security and manage other commercial risks;
  • Carry out market research and analysis, including satisfaction surveys;
  • Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed. Please be aware you have the right to change the perimeters you have expressed.
  • Personalise your experience on the HMD Website by presenting information and advertisements tailored to you;
  • Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully;
  • Facilitate social media sharing functionality;
  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management;
  • Resolve complaints, and handle requests for data access or correction;
  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
  • Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

International Transfers of Personal Information

Personal Information which you supply to us is generally stored and kept inside the European Economic Area.

How can you manage or delete Personal Information?

When you access our website online, we store some information about you within your private area of the website. This is anonymous and used for statistical purposes. Please note that HMD reserves the right to remove your details from our database which include any content that we consider to be illegal or offensive. If you would like to permanently delete your account, you can send an email to our Data Protection Officer (DPO) (see below) with the subject line “Permanently delete my information and account”. Please do not forget to tell us who you are.

Security

HMD is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. Our security measures include: -
  • encryption of our services and data;
  • review if our information collection, storage and processing practices, including physical security measures;
  • restricting access to personal access to personal information to HMD employees, contractors and agents who need to know that information in order to process it for us and who are subject to contractual confidentiality and processing obligations. They may be disciplined or their contract terminated if they fail to meet these obligations; and
  • internal policies setting out our data security approach and training for employees.

Children and minors

HMD is not directed towards individuals under the age of eighteen (18).

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. By using this site we will take it to mean that you are happy to accept our use of cookies. The cookies used on this website serve a variety of functions. There are cookies required for the proper operation of this website and cookies used for monitoring visitor behaviour, cookies that magically vanish when you close your web browser and cookies that stay on your computer/device for months or years.

To prevent the 'cookie' notice that appears when you first visit our website from appearing constantly, cookies are also set. These are called cwallowcookies, which will prevent the cookie notice from appearing again for 1 year. If you move about this site or return to this site, the cookie notice will not be shown as you have demonstrated that you are happy to receive our cookies in order to use this site.

The site uses four Google Analytics cookies for the purpose of visitor behaviour analysis, allowing us to improve our website and understand where our visitors come from. This website uses the following cookies: __utma, __utmb, __utmc and __utmz, one of which will disappear when you close your browser, the others remaining on your computer/device for some months. If you want to learn more about these cookies, please review Google’s privacy policy.

Most web browsers allow some control of cookies via adjustments to the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Your Rights

You have the following rights:

  • the right to ask what personal data that we hold about you at any time, subject to a fee specified by law (currently £10);
  • the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
  • (as set out above) the right to opt out of any marketing communications that we may send you.

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

The data controller responsible for your information is How’s My Driving Limited.

If you have any questions about this policy or our use of your Personal Information you can email: [email protected] or write to the Data Protection Officer, 35/36 Knowledge Centre, Wyboston Lakes, Bedfordshire, MK44 3BY.

If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, are available at https://ico.org.uk

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please take a look at the “LAST UPDATED” date at the top of this Privacy Policy to see when it was last revised.