1. POLICY STATEMENT
1.2 The Data Controller is ALD Automotive Ltd ("ALD", "we", "us" or "our") of Oakwood Drive, Emersons Green, Bristol BS16 7LB. Details of our notification to the data protection regulator may be found in the Information Commissioner's Office Public Register of Data Controllers at www.ico.org.uk under registration number Z5755978.
1.4 Where this supplementary policy includes information that is different from the main Fair Processing Notice, please rely on this supplementary policy in relation to use of ProFleet and the main Fair Processing Notice in relation to all other processing undertaken by us.
2. GENERAL INFORMATION
2.1 This Policy explains what Personal Data we collect about you when interact with our site and/or you register to use ProFleet and how we handle your Personal Data to ensure that we protect your rights. Please read this Policy, alongside our main Fair Processing Notice, carefully to understand how we will treat your Personal Data. In this Policy, references to "you" or "your" shall mean you as a user of ProFleet.
3. INFORMATION WE MAY COLLECT FROM YOU
3.1 We may collect the following personal data relating to users of ProFleet:
- Contact information including name, address, email address and contact telephone number;
- Information relating to your employment which may include your employee number, job grade/title, and contract start/end dates;
- Correspondence received from you (where necessary and only for as long as necessary),
- Details of the vehicle you use for business journeys ("Business Vehicle"),
- Details (via the third party or vehicle manufacturer fitted telematics unit) of:-
- mileage; and
- distance, time, start and end location, speed, acceleration and braking data as standard for all journeys* you make in the Business Vehicle/s registered on your ProFleet account, during the time your account is live.
*Please see section 5 for information on what journeys are actually viewable by your employer
4. HOW AND WHY WE PROCESS YOUR PERSONAL DATA
4.1 in the normal course of our business, to allow us to register you to access ProFleet and to provide you with our services. The provision of your contact information at the point of log-on set-up to ProFleet is mandatory if you are to receive our services;
Lawful bases: legitimate interests (to identify you and communicate with you in the course of providing our services).
4.2 to allow us to manage your ProFleet account and provide the related services;
Lawful bases: legitimate interests (to allow us to administer your account and provide our services to you). Contract Performance (to allow us to perform the contract in place between us or your employer holds with us governing the ProFleet services).
4.3 to allow us to contact you when your Business Vehicle may require servicing or in the event of a manufacturer recall and assist with service booking where provide this separate service to your employer. This aspect of processing does not require a live ProFleet account but occurs if you have completed the registration form on ProFleet;
Lawful bases: legitimate interests (to help ensure Business Vehicles owned by us are safe and properly maintained).
4.4 to allow us to interact with and provide certain information and services within your ThreeSixty account held with us (where applicable);
Lawful bases: legitimate interests (to allow us to administer your account and provide our services to you). Contract Performance (to allow us to perform the contract in place between us or your employer holds with us governing the ThreeSixty services).
4.5 to digitally analyse your journey data and issue related advice to you by email based on that analysis (only where your employer takes the upgraded ProFleet services and has a related consultancy agreement in place with us);
Lawful bases: legitimate interests (to assist you in conducting safe and legal driving practices and your employer in meeting its health and safety legal obligations relating to business journeys).
4.6 to allow us to analyse your personal preferences and personalise our services to you so that we can provide a more tailored experience to you;
Lawful bases: legitimate interests (as part of administering your account and providing the right services to you under the contract in place between us or your employer holds with us governing the ProFleet services).
4.7 We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
Lawful bases: Explicit consent, which will be obtained from you in the event that you wish to complete a survey.
4.8 From time to time we may contact you with details of and our products and services and related offers.
Lawful bases: Explicit consent, in relation to your marketing preferences
4.9 We will endeavour periodically to check that the personal data we store for you is accurate. If you would like to update the personal data we hold about you, please do so through whichever means is appropriate to your account e.g. through ThreeSixty or by contacting the relevant Customer Support team.
Lawful bases: legal obligation (under the General Data Protection Regulation) or legitimate interests (to assist us in providing our services to you).
4.10 From time to time, the journey and Business Vehicle data collected on your ProFleet account may be used and transferred to third parties to conduct general data analysis but only ever in an anonymised form, such that it does not constitute personal data.
Lawful bases: N/A as the data will always be anonymised to the extent that it does not constitute personal data.
5. WHO DO WE SHARE YOUR INFORMATION WITH?
5.1 As part of using our services, you agree to us sharing a subset of your Personal Data with the following parties, to assist us in achieving the purposes outlined at section 4 above:-
- to your employer (i) as part of the provision of the ProFleet services (ii) if your employer informs us that Business Vehicle has been retained by you without its authority or (iii) they require with legitimate interests your Business Vehicle location data in the event of an emergency;
- journey data will only be viewable by your employer via its Fleet manager view ProFleet account in respect of the journey type i.e. business and/or private depending on which journey type(s) you have given your permission for your employer to view. Your employer will have determined a default journey type setting when entering into the agreement with us for ProFleet services. You will be made aware of that default setting and if the default journey type is business, you must ensure that you allocate journeys as private via your ProFleet account as swiftly as possible, particularly where your employer is not authorised to view private journeys;
- to any member of our Group of companies, which includes our subsidiaries, our ultimate holding company and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006), where required to manage your ProFleet account, perform the contract with you or your employer governing the ProFleet services, for storage or as part of general data stability analysis;
- our current third party service provider, in order to retrieve or provide telematics information in relation to a Business Vehicle as required to perform the ProFleet services;
- insurers in relation to accidents and/or damage relating to the Business Vehicle;
- professional advisors in order to review, perform or refine the ProFleet services provided and as necessary for the establishment, exercise or defence of legal claims;
- the Police, where we have reasonable cause to believe the Business Vehicle has been stolen (and generally, as may be required by law – see below); and
- other third parties where:
- our business, either in whole or in part, is acquired by a third party (in which case Personal Data about customers will be one of the transferred assets); or
- we are under a duty to disclose or share your personal data by law or regulation (including but not limited to the Police and in the event of a road traffic accident involving a fatality, the Vehicle and Operator Services Agency (VOSA), and any other government agencies as requested
6. COOKIES POLICY
· Our Cookies Policy is accessible via: https://www.aldautomotive.co.uk/mobility-solutions/support-services/telematics/profleet-cookie-policy
. Details as to how to manage your Cookies preferences can be found in our Cookies Policy.
7. LINKS TO OTHER WEBSITES
ProFleet may, from time to time, contain links to and from the websites of our partner networks 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.
Other useful documentation
Please see also the following documents for further information:
8. Contact Us
Questions, comments and requests regarding this Policy are welcomed and should be addressed to The Data Protection Officer, ALD Automotive Limited, Oakwood Drive, Emersons Green, Bristol BS16 7LB. You can also email the Data Protection Officer via: email@example.com.