Privacy Policy/Fair Processing Notice

1. Policy Statement

1.1. This Privacy Policy/Fair Processing Notice (the “Policy”) relates specifically to all users of the ThreeSixty site (“ThreeSixty”).

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 http://www.ico.org.uk under registration number Z5755978.

1.3. This Policy is supplementary to our main Privacy Policy/Fair Processing Notice, which includes detailed information setting out how we will handle your personal data securely and in accordance with your rights.

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 ThreeSixty 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 you register to use ThreeSixty and/or use our services 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 ThreeSixty.

3. Information we may collect from you

3.1. We may collect the following personal data relating to users of ThreeSixty:

Contact information including name, address, email address and contact telephone number;
Information to assist us in identifying you with certainty including national insurance number and date of birth;
Information relating to your employment including employee number, job grade, tax and NI band rates payable and cash allowance provided and contract start/end dates;
Information about your use of ThreeSixty, for example the pages viewed, last login date and the website from which you came to visit ThreeSixty including by use of cookies (see our Cookies Policy);
Details of the quotes you request and your transactions,
Correspondence received from you (where necessary and only for as long as necessary),
Details of any endorsements on and the status and category of your driving licence (only if our licence checking services are being provided),
Eyesight test declaration records (only if our eyesight test declaration recording service is being provided),
Details of any driver training online or practical courses you attend/complete (only if our driver training services are being provided),
Your vehicle details where your company car is provided by ALD or where your own car details are required for provision of our grey fleet (employee-owned used for business purposes) risk analysis service known as CARRS,
VED expiry date (for CARRS service only),
MOT details (for CARRS service only),
Identity of your insurer and policy details (for CARRS service only),
Levels of your business and private mileage; and
Your Fuel card spend, details of Fuel card transactions and details of vehicle journeys in relation to the vehicle linked to your Fuel card (only you will be able to view journeys you have marked as personal)

4. How and why we process your personal data

A summary is set out below of the purposes of processing of your personal data, the third parties it may be shared with, and the lawful bases we may rely on in order to process it. This is in addition to the data described in the main Privacy Policy/Fair Processing Notice

4.1. in the normal course of our business, to allow us to register you to access ThreeSixty and to provide you with our services. The provision of your contact information at the point of log-on set-up to ThreeSixty 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 ThreeSixty account;

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 services provided via the ThreeSixty sIte)

4.3. 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 services provided via the ThreeSixty sIte)

4.4. 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

4.5. 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 via your ThreeSixty log-on.

Lawful bases: legal obligation (under the General Data Protection Regulation) or legitimate interests (to assist us in providing our services to you)

4.6. We may also, where applicable, process the Criminal Convictions Data listed in section 3 above (driving licence status and endorsements)

Lawful bases: Explicit consent (given by you via your employer, in order for us to perform the licence checking ThreeSIxty service) or such processing is necessary for the establishment, exercise or defence of legal claims.

5. Who do we share your information with?

5.1. As part of using our services, you consent to us sharing a limited subset of your Personal Data with the following parties, to assist us in achieving the purposes outlined at section 4 above:

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 ThreeSixty account, perform the contract with you or your employer governing the ThreeSixty services, for storage or as part of general data stability analysis;
DriveTech (UK) Limited (part of the AA Group) in order to create and manage users on their FleetRiskManager system to provide the driving licence checking and driver training ThreeSIxty services;
Airmax Group Limited or Trackm8 Limited in order to retrieve or provide telematics information in relation to a Vehicle; and
professional advisors in order to review, perform or refine the ThreeSIxty Services provided and as necessary for the establishment, exercise or defence of legal claims.
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 with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

6. Cookies Policy

Our Cookies Policy is accessible via Cookies Policy. Details as to how to manage your Cookies preferences can be found in our Cookies Policy.

7. Links to Other Websites

ThreeSixty may, from time to time, contain links to and from the websites of our partner networks and affiliates. For customers who have taken services from the DriveSafe suite of products, this will include a link to our partner provider for this service. 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.

In all other respects, we process your personal data in accordance with the main ALD Privacy Policy/Fair Processing Notice

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, Emerson’s Green, Bristol BS16 7LB. You can also email the Data Protection Officer via dpo@aldautomotive.com