We are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the General Data Protection Regulation, the data controller is Trak Global Group Limited, Global House, Westmere Drive, Crewe Business Park, Crewe, Cheshire, CW1 6ZD.
Basis for Processing
We will use our best endeavours to ensure that we process information you provide to us only in accordance with your consent. In certain circumstances, however, if you are a current or past customer that has bought goods or services from us, we will rely on a legitimate interest exemption and will continue to process your personal data for marketing purposes unless you inform us otherwise.
Information We May Collect from You
We may collect and process the following data about you:
- information that you provide by filling in forms on our site or on any mobile applications we may provide. This includes information provided at the time of registering to use our site, subscribing to our services or requesting further services (where applicable);
- we may ask you for information when you report a problem with our site.
- if you contact us, whether by email or by post, we may keep a record of that correspondence.
- we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
For system administration purposes we may collect information about your computer, including where available your IP address, operating system and browser type, or the type of mobile phone or smart device used. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. However, we will treat this information as if it was personal data and will take appropriate steps to ensure its safety and security.
Where We Store Your Personal Data
All information you provide to us is stored on our secure servers in the United Kingdom.
However, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. In the event that this happens, we will inform you of how the data will be protected and how you can obtain further information regarding the safeguards we put in place.
Uses Made of Your Information
We will process information held about you in the following ways:
- to ensure that content from our site is presented in the most effective manner for you and for your computer, mobile phone or smart device.
- to provide you with information, products or services that you request from us or which we feel may interest you where you have consented to be contacted for such purposes.
- to carry out our obligations arising from any contracts entered into between you and us, or to allow us to enter into a contract with you.
- to allow you to participate in interactive features of our service, when you choose to do so and if available.
- to notify you about changes to our services.
Where you have consented, we may also use your data, or permit selected third-parties to use your data, to provide you with information about goods and services which may be of interest to you, and we or they may contact you about these using the contact details you have provided at the time of registration.
Use of the IMS OneApp smartphone app
If you use the IMS OneApp smartphone app we will need to collect, access and share data from your mobile device for the purpose of app functionality and performance improvements.
The app will access personal data on your mobile device through:
Information you provide to us (i.e. photo uploads)
- Information held on your mobile device (e.g. Phone model, device ID and OS version)
- Information you have permitted the app to access via app permissions
The app will access/collect the following data:
- Device background location through network and GPS (to enable the app to automatically detect trips)
- Camera (to enable documents to be submitted through the app)
- Phone calls and read status/ identity (to allow phone calls to be made through the app)
- Wifi, Bluetooth, and network status and connections
- Phone model, Device ID and OS version
We will share your personal data with Third Parties for the purpose of calculating driving style scores, assessing the performance and stability of the app and improving the features and performance of the app. Your Driving data may be used by Third Parties on our behalf for the purpose of analytics and improving app functionality however will be anonymised before being shared for this purpose.
Disclosure of Your Information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
It may be necessary for us to disclose your personal information to third parties in the following circumstances:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets – we will endeavour to anonymise this data prior to any disclosure taking place.
- if we or any of our group companies, or substantially all of its or their assets are acquired by a third party, in which case personal data held may be one of the transferred assets.
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of website use and other agreements.
- to protect the rights, property, or safety of our customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will retain your personal data only for as long as is necessary for us to give effect to your wishes. We will periodically review the data we hold with a view to deciding whether it is appropriate to continue to retain it. Where we have, or one of our group companies has, not entered into an on-going contract with you, we anticipate that your personal data will be deleted after 12 months. Unless you have expressly informed us that you do not wish to be contacted, we may contact you prior to the deletion of your data to ask you whether you consent to us continuing to hold your data.
You have the right to ask us not to process your personal data for marketing purposes. We will ask you for your consent before collecting your data and will inform you if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You are under no obligation to consent to the use of your personal data in this way. We will only process your personal data where you have ticked certain boxes on forms, we use to collect your data or where we have a legitimate legal interest in processing your data.
Where you have consented to us processing your personal data, you can change your mind and withdraw consent to us using your personal data for this purpose at any time. You can do this by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to Information and Porting of Data
You have the right to access a copy of the information we hold about you, and to ask us to rectify any information which we hold which is incorrect. We will endeavour to respond to any request for information without undue delay and will respond at the latest within one month of the date we receive your request. If we will be unable to meet your request within this timescale, we will write to you setting out the reasons why. We reserve the right to ask you to specify the information or processing activities to which your subject access request relates.
Any access request will be free of charge, although we may charge you a reasonable fee to meet our administration costs if you request further copies of the same information.
Unless you inform us otherwise, we will provide you with the information you request electronically in a form which is commonly machine-readable.
Where you have given your consent to the processing of your personal data, you have the right to request that we transfer your data to another data controller. Where we receive such a request, we will provide you with a copy of all personal data we hold about you in a commonly machine-readable format so that you can transfer this data directly to another data controller, following which we will, subject to any legally-mandated retention obligations, delete your personal data. Where it is technically feasible for us to do so, we may be able to transfer your data directly to another data controller.
We reserve the right to decline to transfer your personal data to another data controller where to do so would materially prejudice any of our proprietary intellectual property rights or would result in the disclosure of our trade secrets to a third party. If we believe that a transfer will result in this, we will work with you to ensure that we can transfer as much of your personal data as possible.
Please help us to keep your personal details up to date by promptly notifying us of any changes, for example, if you change your address or telephone number. If you need to change your personal details or preferences at any time, please contact us (please see the ‘Contact us’ section of this policy).
You have the right to complain to the Information Commissioner at www.ico.org.uk, Tel 0303 123 11132.
If you have any questions, comments or requests regarding this policy, please contact us at:
Telephone: 01270 501212
Post: Trak Global Group Limited, Global House, Westmere Drive, Crewe, CW1 6ZD