Transport Exchange Group Privacy Policy – Transport Exchange Group

Background: who we are

This Policy applies to all users of the online platforms (defined below) developed by the Transport Exchange Group Ltd (“We“, “Us”, “Our” etc).  Please note that a separate privacy notice applies to users of the mobile applications developed by Transport Exchange Group, which can be found here.

Your privacy is important to us, so We have 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.

Transport Exchange Group Ltd, which owns courierexchange.co.uk, haulageexchange.co.uk, CXEURO.com, courierexchange.mobi, transportexchangegroup.com and other onlineplatformsand applications belonging to Us or to our affiliate(s)from time to time (referred to herein as the “Platform(s)”) 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 (UK and EU versions) and the Data Protection Act 2018 (collectively the “Data Protection Laws”) the Data Controller is Transport Exchange Group Ltd.

Collecting your personal data

2.1 Your personal data that we collect from you

We collect and process some or all of the following types of information from you in the course of your use of the Platforms or providing Our services:

Information that you provide by filling in forms on the Platforms or filling in forms as part of the registration process, verbally, via email or any other medium. This includes information provided at the time of registering to use the Platforms, subscribing to and using our service, or requesting further information or services.
We may also ask you for information when you for example report a problem with the Platforms.
This could include, but not limited to, passport or other identity document, driving licence, full name, date of birth, email address, contact details, residential address, images of your vehicle, vehicle registration number, vehicle insurance certificate, vehicle rental agreement, operator’s licence, bank details, name of director (for businesses), or any other information entered when using the Platforms, completing our survey forms, or using our services.
If you contact us, 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 the Platforms including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

2.2 Special categories and other sensitive data we collect from you

We do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, or genetic data.

We conduct live facial recognition checks via the Trustd app in order to confirm your identity against your identity documents.

2.3 Your personal data that We collect from other sources

We will obtain personal data from other sources as follows:

From our affiliate when you use the Trustd app owned by our affiliate Managed Identities Limited to obtain verification reports.
Publicly available sources which include, but are not limited to, Google, Companies House and social media platforms.

Private sources such as Creditsafe.
From our insurance partners from whom you have obtained a policy, and where you have given appropriate permissions, in order for us to check that you have appropriate insurance policies in force.
DVLA and other driving license records providers.
Compliance check providers.

We collect information about any driving offences and points on your driving license as part of our compliance check service. 

Lawful basis for processing

Consent / Performance of a contract

Where you are the person asking for Our services, we rely on consent for processing sensitive personal data and both ‘consent’ and the ‘performance of a contract’ for processing your personal data. We are unable to provide the services if you do not consent so please discontinue use of Our website if you do not consent.

We rely on “performance of a contract” to collect, use and share (in accordance with this policy only) your personal data in order to provide Our services pursuant to an agreement with you or your employer. If your employer has asked us for these checks, they must have their own privacy policy in place. If you object to this, please discontinue use of Our website and take this up with your employer.

If you are entering personal data of your employer’s staff on behalf of your employer, you must ensure that you have a lawful basis under applicable data protection laws to do so. If you are unsure whether you have this, please discontinue use of Our website and take this up with your employer.

We rely on “performance of a contract” to share with our sub-processor Managed Identities Limited any personal data included in information provided by you as part of an application for membership of the Platforms and updates to such information provided by you from time to time. Managed Identities Limited (via the Trustd app) will ask you and retrieve from other sources for your personal data which may include your driving records including offences. The information you provide to them enables Us to provide you and / or your employer with legally required compliance checks in the public interest and for the prevention of dishonesty that permit you to provide your services through our platform. Managed Identities Limited will process such information in accordance with their privacy policy which will be made available to you when you enter your data on Trustd and is also available here.

Should you use our invoice factoring services, we will share your data with Penny Freedom& ClearFactor or any other invoice factoring providers we may add to platform from time to time.

We redirect you to our payment provider Modulr Finance or a replacement provider from time to time so that they can take payment on our behalf. Modulr Finance, as a data controller in their own right, will ask you for your payment details. They will then send us information confirming whether you have paid so that We can subsequently provide you with our services. Modulr Finance will process such information in accordance with their privacy policy available when you make payments, and on their website here.

Legitimate interest

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 an organisation that has engaged you;

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; or

We may collect, use and share (in accordance with this policy only) your personal data in order for you to receive services from a service provider pursuant to an agreement entered between you and the service provider.

Marketing to our customers (soft opt-in)

We and our related companies may send you newsletters and promotional materials from time to time with regard to similar services because you are our customer. You can opt out of these at any time via the “unsubscribe” link provided in each promotional email or newsletter.

Marketing of third-party goods or services with your consent

Should We ever share your information with third party advertisers, We will ask for your consent beforehand, which would be the lawful basis. You do not have to agree and if you do, you may change your mind and opt out at a later date using the method provided by the relevant third party.

Surveys

We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey.

Purposes of processing

We use information held about you in the following ways:

To provide you with our services.

To ensure that content on the Platforms is presented in the most effective manner for you and for the device(s) you use to access and view the Platforms;
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 / your employer.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our services.

To enable Us to refer you to our business partners or share your data with third parties, where you have authorised or asked Us to do so.
For marketing our products and services and similar products and services.

Disclosure of information

We routinely disclose your personal data to third parties as follows:

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, provide compliance or payment services);

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) and to our affiliates;
Where you have agreed 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 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;

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;
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;
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 Platforms;
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;
in relation to our insurance partners, to enable us to refer you to them where you have authorised or asked Us to do so.

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.

6. Storing your personal data

We take appropriate measures to ensure that any personal data is 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 websites/applications, 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 (by email) and any applicable regulator via the correct channels of a 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.

The Platforms 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 terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your data up to date

If your personal details change you may update them by accessing the relevant page of the Platforms, 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.

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 six 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

Transport Exchange Group makes use of cloud computing platforms and third-party service providers to deliver its services. This may involve storing or transferring your personal data outside of the UK and the EEA.

When we transfer or store the information that We collect from you at a destination outside the European Economic Area (“EEA”),it is 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, fulfilling your orders, undertaking compliance checks, processing your payment details and providing support services. By submitting your personal data, you agree to this transfer, storing or processing.

In countries that do not have the same data protection laws as the United Kingdom and EEA, we ensure that any personal data being transferred has an adequate level of data protection similar to that which applies in the United Kingdom and EEA, and any transfer of your personal data is subject to an agreement with these third parties approved by the UK Information Commissioner’s Office.

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.

10.Your rights

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 member ID, 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.

Changes to our privacy policy

We reserve the right to modify this policy at any time. Any changes We may make to our policy in the future will be notified and made available to you using the Platforms. Your continued use of the services and the Platforms shall be deemed your acceptance of the varied privacy policy.

13. Cookies and IP addresses

We may collect information about your mobile phone, computer or other device from which you access the Platforms including where available your IP address, operating system, screen size and resolution, and browser type, 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.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies We use include:

Analytical cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Platforms when they are using it. This helps Us to improve the way our Platforms work, for example, by ensuring that users are finding what they are looking for easily.
Strictly necessary cookies. These are cookies that are required for the operation of our Platforms. They include, for example, cookies that enable you to log into secure areas of our Platforms, or cookies that let us know you have accepted this privacy policy.
Functionality cookies. These are used to recognise you when you return to our Platforms. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our Platforms, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Platforms, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Please note that third party affiliates may also use cookies, over which We have no control.

More information about the cookies we include and how to manage them can be found here:

Cookies which are strictly necessary for the core functionality of the Platforms are enabled by default, and set automatically at the point you access the Platforms.

Any cookies which are not strictly necessary for the functioning of the Platforms will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Platforms.

14. Contact

All questions, comments and requests regarding this privacy policy should be addressed to Transport Exchange Group Ltd at the following address, or via

support@transportexchangegroup.com:

20 Northdown St, London N1 9BG

Last Update: 22ndNovember 2022

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