This Policy applies to all users of Mobile Applications (each referred to herein as the “Mobile App”) developed by the Transport Exchange Group.
Your privacy is important to us, so we've created a policy that covers how we collect, use and store your personal data. Please take a moment to familiarise yourself with our privacy practices.
Where you are authorised to use the Mobile App by an organisation that has engaged you to perform courier or other services ("Authorising Company"), in addition to Our use of your personal data as set out herein, we may process your personal data on behalf of the Authorising Company (in this case we are a data processor). You should contact the Authorising Company to find out what they do with your personal data.
Transport Exchange Group Ltd, which shall include but not be limited to courierexchange.co.uk, haulageexchange.co.uk, CXEURO.com, courierexchange.mobi, transportexchangegroup.com (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected 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 purpose of the General Data Protection Regulation and the Data Protection Act 2018 (collectively the “Data Protection Laws”) the Data Controller is Transport Exchange Group Ltd.
Your personal information
We collect and process some or all of the following types of information from you in the course of your use of the Mobile App or providing our services:
- Information provided in connection with the registration of your account either by you or by an organisation that has authorised you to use our Mobile App ("Authorising Company"). This includes:
- Email address
- Telephone number
- Login details
- Vehicle registration number
- Insurance details
- Information that you provide to Us either via your account, orally, via email or via any other medium. This may include information provided when you request further information or services, or report a problem with the Mobile App.
- If you contact Us, We may keep a record of that correspondence.
- Information collected automatically via the Mobile App, which includes the following:
- Location data - We use GPS technology, cellular data and IP addresses to determine your current or approximate location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location data in your settings, although carriers and brokers cannot fully use the Mobile App If they do not permit location data collection. Location data will be collected both when you are using the Mobile App, and when the Mobile App is running in the background.
- Service information - this includes the type of services requested or provided by you, date and time the service was provided, any photographs uploaded by you.
- Device data - We collect data about devices used to access our services which is used by Our customer support team to provide support to you.
- Usage data - how you interact with our services (including analytics that we or third parties, such as Google Firebase, conduct to improve our services), dates and times you access the Mobile App, or other system activity.
Uses made of your information
Lawful basis for processing
We rely on “performance of a contract” on which we collect, use and share (in accordance with this policy only) your personal data in order to provide our services or to receive your services pursuant to an agreement with you.
We rely on “legitimate interest” where:
- We collect, use and share (in accordance with this policy only) your personal data in order to provide our services pursuant to an agreement with the Authorising Company;
- We use and process your contact details to correspond with you to build a potential business relationship, including providing you with materials and information we feel may be of interest to you;
- We may use your data to improve or enhance the safety and security of our services and users, to improve your user experience, or to prevent use of our services for prohibited or illegal purposes.
Purposes of processing
We use information held about you in the following ways:
- To provide you or the Authorising Company with our services.
- To ensure that content on the Mobile App is presented in the most effective manner for you and for the device(s) you use to access and view the Mobile App;
- To provide you with information and offers that you request from Us or which We feel may interest you.
- To carry out our obligations arising from any contracts entered into between Us and you or any Authorising Company.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
Disclosure of information
We routinely disclose your personal data to third parties as follows:
- Where you are authorised to use the Mobile App by an Authorising Company, we will share you Information with the Authorising Company.
- Where we have agreed for you or the Authorising Company to use the services of a service provider that is registered with Us, we may share your information with such service providers in order for them to provide you with their services.
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers);
- We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable);
We may also disclose your personal data to third parties:
- 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; or
- if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
- 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 and Conditions and other agreements; or
- to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Mobile App; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you
- Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so
Storing your personal data
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Mobile App, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the website or our application; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your data up to date
If your personal details change you may update them by accessing the relevant page of the Mobile App, or by contacting Us using the contact details below.
If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
We will endeavour to update your personal data within 14 working days after receipt of relevant documents, and/or updating of necessary databases, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold personal data including but not limited to name, address and contact details for the period we are required to retain this information by applicable UK tax law currently seven years.
We may store other personal information that you have provided us for as long as it is reasonably necessary taking into consideration our need to provide you with the services you have signed up to, to resolve any disputes, enforce our rights and/or respond to queries.
If you have any questions about our data retention policy please contact Us.
Where we store your personal data
All information We hold about you is stored on our hosted secure servers within the EEA.
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 maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Such countries do not have the same data protection laws as the United Kingdom and EEA and we will ensure that any personal data being transferred have an adequate level of data protection similar to those which apply in the United Kingdom and EEA, and any transfer of your personal data will be subject to an agreement with these third parties, which we will have reviewed, approved and/or negotiated.
If you would like further information, please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which we hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to Us (see ‘Contact’ below)
- let Us have enough information to identify you for example account number, user name, registration details.
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates, including any account or reference numbers, if you have them
Making a formal complaint
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone 0303 123 1113.
Cookies and IP addresses
We may collect information about your mobile phone, or other device from which you access the Mobile App including where available your IP address, operating system, hardware model, screen size, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
We only use strictly necessary cookies that are required for the operation of our Mobile App. They enable Us to authenticate your details for you to be able to use our Mobile App.
Cookies which are strictly necessary for the core functionality of the Mobile App are enabled by default, and set automatically at the point you access the Mobile App.
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