This privacy notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how we at the ETA use your data; for example, we will explain things such as our credit checking procedure, and how we combine data across our services to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this privacy notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
When you are using our ETA websites, ETA Services Ltd is the data controller.
What is the ETA?
The ETA is made up of a number of related organisations:
- ETA Services Ltd – this runs the main insurance services
- ETA Trust Ltd – this is our charity.
- Environmental Transport Association Ltd – this is our campaigning organisation.
- ETA Publications Ltd – this provides printing services.
For simplicity throughout this notice, ‘we’ and ‘us’ means the ETA and its associated partners above.
How does the law provide for the arrangement between me and you?
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you have our breakdown service, we’ll collect your vehicle details, and pass them to our vehicle recovery operator.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the ETA to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers. We also combine the purchase history of many customers to identify trends and ensure we can keep up with demand or develop new products/services. We will also use your email address details to send you direct marketing information by email, telling you about products and services that we think might interest you.
When do you collect my personal data?
- When you visit our website and use your account to buy products and services.
- When you visit our website (in which case we just collect transaction-based data).
- When you create an account with us.
- When you engage with us on social media.
- When you download or install one of our apps.
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you choose to complete any survey we send to you.
- When you comment on or review our products and services.
- When you fill in any forms. For example, if you make a claim, we or one of our agents may collect your personal data.
- We collect data from publicly-available sources (such as DVLA) when you have given your consent to share information or where the information is made public as a matter of law.
What sort of personal data do you collect?
- If you have a web account with us: your name, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through the contact centre, online or by using one of our apps. For example, we record most of our telephone conversations with you, details of any complaints or comments you make, details of purchases you made, products to have considered, web pages you visit and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this.
- Details of your purchase preferences. For example, what time you like to purchase over the internet.
- Details of your visits to our website or app, and which site you came from to ours.
- Personal details which help us to recommend items of interest. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your purchase experience with us. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and why do you use my personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website or app. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to verify that you are entitled to service that you have paid for, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as claims, warranties and so on.
- To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you log in and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time by unsubscribing from our emails.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this privacy notice, and legally required information relating to your orders. These service messages do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s session ID to help us understand more when you leave us online feedback about any problems you’re having.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the ETA, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which content to share with you. We also use data from customer purchase histories to identify trends in different areas of the country.
How do you protect my data?
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How long do you keep my personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
- When you place an order, we’ll keep the personal data you give us for five years, so we can comply with our legal and contractual obligations.
- If you order is an insurance product, the associated personal data will be kept until the end of the liability we have for you or a third party.
Who do you share my personal data with?
Our service providers – We work with partners, suppliers, insurers, aggregators and agencies so that they can help us provide the products and services you require from us and, are required to meet our high standards of security. We only share information that allows them to provide their services to us or to facilitate them providing their services to you. These third parties include claims administrators, underwriters, vehicle recovery operators and fraud management.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Our third parties privacy policies may be accessed here:
Examples of the kind of third parties we work with are:
- Informatics companies who support our website and other business systems.
- Claims administrators
- Call centres
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact our Data Protection Officer.
We do not share your data with third parties for their own purposes at all and have never done so.
To help personalise your journey through the ETA’s website we currently use the following companies, who will process your personal data as part of their contracts with us:
- Affiliate Window
Where may my data be processed?
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as America or Australia.
Protecting your data outside the EEA.
The EEA includes all EU member states as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What are my rights over my personal data?
An overview of your different rights.
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that the ETA holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact firstname.lastname@example.org or Customer Care, ETA Services, 68 High Street, WEYBRIDGE KT13 8BL. To ask for your information to be amended, please update your online account, or contact our Customer Care team.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How can I stop the use of my data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular part of our business.
- In our apps, you can manage your preferences and opt-out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
- Write to Customer Care, ETA Services, 68 High Street, WEYBRIDGE KT13 8BL or by email: email@example.com.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
How does this website use my personal data?
IP addresses and cookies
We may collect information about your computer, including your IP address. This is statistical data about our users’ browsing actions and patterns, and this information will not identify the individual.
We may obtain information about your general browsing usage by using cookies. Cookies are small software files, which are placed by a website onto the computer, telephone or other devices which has access to the website.
We will place cookies on any computer, telephone or devise that you use to access the website. The cookies will enable information to be stored on your device and sent to and from the website and your device.
Cookies are in place to help us improve the website and to deliver a better and more personalised service. They help with estimating our audience size and patterns of usage and along with your preferences, which allow us to customise our website according to your individual interests.
You reserve the right to accept or decline cookie tracking. This can be done by not accepting our terms and conditions or by activating the settings of your browser which allows you to refuse the setting of cookies.
Third party sites
How can I contact the regulator?
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we are not responsible for the content of external websites).
What if I have more questions?
We hope this privacy notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our data protection officer who will be pleased to help you:
- Email us at firstname.lastname@example.org
- Or write to us at Customer Care ETA Services, 68 High Street, WEYBRIDGE KT13 8BL.
This notice was last updated on 07/09/2018