Sheen Mobility (“we”, “us” and “our”) are committed to protecting and respecting your privacy, as required under the General Data Protection Regulation (GDPR).
Our Privacy Notice applies to all applications and services offered by Sheen Mobility.
Please read our Privacy Notice carefully as it describes our collection, use, disclosure, retention and protection of your personal data. This notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal data in any of the ways described in section 1 below, you agree that we may collect, store and use it:
- (a) in order to perform our contractual obligations to you;
- (b) based on our legitimate interests for processing (such as for internal administrative purpose or to provide information around products and services that we provide);
- (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice
How we collect personal data
To the extent permissible under applicable law, we collect personal data about you and any other party whose details you provide to us when you:
- fill in forms on our site (such as our ‘Contact Us’, ‘VAT Exemption Declaration + T&C’s’ Forms). This will include personal data such as your name, contact details and any further personal data you provide in relation to your query;
- open an account or while logged in to your existing account. This may include personal data such as your name, contact details or other identification details and financial personal data;
- complete any surveys or enter any competitions;
- interact with us using social media;
- provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details; and
- contact us offline, for example by telephone, SMS, email or post.
We will also collect your personal data where you only partially complete and/or abandon any personal data inputted into our website and/or other online forms and may use this personal data to contact you to remind you to complete any outstanding personal data and/or for marketing purposes.
We may enhance personal data we collect from you with personal data that we receive from other sources in the course of providing services to you (including, for example, personal data received from other companies within our group, business partners, any sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search personal data providers and credit reference agencies).
If you give us personal data about someone else, you are responsible for ensuring that you comply with any consent obligations under applicable data protections laws. In so far as required by applicable data protection laws, you must ensure you have their explicit consent to do so before providing that information and that you explain to them how we collect, use, disclose and retain their personal data or direct them to read our Privacy Notice.
How we use your personal data
We may use your personal data for any or all of the following reasons:
- to respond to any specific queries, carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products and services that you request from us;
- manage and administer your use of applications, products and services you have asked us to provide;
- manage our relationship with you (for example, customer services and support activities);
- monitor, measure, improve and protect our content, website, applications and services and provide an enhanced personal user experience for you;
- provide you with any personal data that we are required to send you to comply with our regulatory or legal obligations;
- contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
- to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
- deliver targeted advertising, marketing or information to you which we reasonably believe may be useful to you, based on your use of our applications and services;
- provide you with location based services (for example, advertising and other personalised content), where we collect geo-location data;
- to identify accounts and provide information to appropriate authorities (e.g. HMRC) as part of an ongoing enquiry.
We retain personal data that has been provided after the closure of any account, following a decision by us not to offer an account or if you decide not to proceed. This personal data will be held and used for as long as necessary for legitimate business purposes and no longer than the timeframe permitted by regulation and current law.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
- check specific personal data from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- obtain personal data relating to any technical errors or other issues with our website, applications and services;
- collect personal data about how you and users use the functions of the features of our website, applications and services; and
- gather statistical personal data about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our forms (where applicable).
We may monitor and record our communications with you, including e-mails and phone conversations. Personal data which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Sharing your personal data
As the data controller for information that you have provided to us, we take our responsibility to protect that data seriously. We will only share your data with third parties where we believe there is a clear legitimate interest in doing so, that will be of likely benefit to you. As part of this, we may share your personal data with:
- third parties used to facilitate payment transactions, for example banks;
- any other relevant third parties in order to meet our legal and regulatory obligations.
We may share non-personally identifiable personal data about the use of our website, applications, products or services publicly or with third parties but this will not include personal data that can be used to identify you.
Your personal data and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
- the right to be told how we use your personal data and obtain access to your personal data;
- the right to have your personal data rectified or erased or place restrictions on processing your personal data;
- the right to object to the processing of your personal data in most instances, e.g. for direct marketing purposes;
- the right to have any personal data you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”) and where you request this;
- where the processing of your personal data is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).
If we hold any personal data about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date. We may periodically ask that you review your data to ensure that the information we hold is correct. We will not do this if you have asked us not to communicate with you.
If you withdraw your consent to the use of your personal data for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our websites, applications, and services.
We will retain your personal data for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the London Wheelchair Hire Ltd. Data Retention and Destruction Policy or as otherwise permitted applicable laws and regulation. Where we no longer need your personal data, we will dispose of it in a secure manner (without further notice to you).
Changes to our privacy notice
We may change our Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated our Privacy Notice).
Security and storage of personal data
We will keep your personal data secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal data but we cannot guarantee the security of your personal data which is transmitted to our website, applications or services or to other website, applications and services via any medium that you provide information to use. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will never intentionally share this password with anyone.
Personal data that we process for any of the purposes outlined above shall not be kept for longer than we believe is necessary for those purposes.
If you believe your account has been compromised, please contact us for the attention of and we will take necessary steps to reset your password.
Other sites and social media
If you follow a link from our website, application or service to another site or service, to a third party company, this notice will no longer apply. We are not responsible for the personal data handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.
Our websites, applications or services may enable you to share personal data with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal data retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal data you enable us to access from that account.
Cookies, Analytics and Traffic Data
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
Performance cookies and analytics technologies
These cookies collect personal data about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don’t collect personal data that identifies a visitor or user. All personal data these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.
These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The personal data these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Web beacons and parameter tracking
IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device personal data, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
Find out more about the individual cookies and analytics technologies that we use.
“How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).
How to disable cookies
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services.
If you have any queries about the information that we hold about you, how we treat your information, the contents of this notice, your rights, how to update your records or how to obtain a copy of the personal data that we hold about you, please contact us via phone or email.