1. Introduction
1.1 Who are we?
1.2 Reasons for holding and using your personal data
2. How we use your information
2.1 When you submit an enquiry via our website or over the phone
2.2 When you purchase a product from us via our website or over the phone
3 Your rights as a data subject
4 Your right to complain
5 Updates to this privacy policy
RED Driving School is committed to protecting your privacy and maintaining the security of any personal data received from you. We strictly adhere to the requirements of the data protection legislation in the UK.
This privacy policy tells you about the information we collect from you when you use our website or make an enquiry with us by telephone. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
We are RDS Driving Services Limited, a company registered in the United Kingdom under number 07372476. Our registered address is Pavilion 6, Coxwold Way, Belasis Technology Park, Billingham, TS23 4EA. You can contact us by post at the above address or by email to info@go-red.co.uk
Our Data Protection Officer can be contacted at the above address or by email to dataprivacy@go-red.co.uk
The reasons for using your personal data are detailed below. We have arranged them according to the legal reason we are allowed to use the data.
1. To provide you with our products or services or allow you to decide whether to purchase them:
(a) Communicating with you and holding records about our dealings and interactions with you;
(b) To manage the operation of our business;
(c) To enable other RED group companies to provide you with your products and services, quote for products and services, or manage products and services you buy from us;
(d) To share information as needed with business partners such as driving instructors and trainers, as required, to deliver the products and services you have purchased.
2. For our legitimate interests:
(a) To continually develop, improve and manage our products and services;
(b) To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to present to you;
(c) To test and improve the performance of our products, services, processes and systems;
(d) To improve the operation of our business – and that of our business partners – for example, by improving customer service and operational performance and efficiency;
(e) To develop new products and services, and to review and improve current products and services;
(f) For management and auditing of our business operations – including accounting;
(g) To monitor and to keep records of our communications with you and our staff (see below);
(h) To understand our customers, their use of our products, their preferences and develop models, including developing profiles and statistical models;
(i) To send by SMS, email, phone, post, social media and digital channels such as Facebook, etc. relevant information updates or advice specific to you or more general marketing offers which may relate to any of our products and services as well as to any other offers we think may be of interest to you;
(j) For market research, profiling, analysis and developing statistics;
(k) To facilitate the sale of one or more parts of our business;
(l) To share information with business partners as necessary for the purposes listed in this notice; and
(m) To share information with other RED group companies to enable them to perform any of the above purposes.
3. To comply with legal obligations:
(a) as governed by applicable UK law.
2.1.1 What personal data do we collect?
When you submit an enquiry via our website, by calling our contact centre, or accessing our App, we store your, name, address, phone number and email address and any additional relevant personal information you may provide us with as part of that enquiry.
2.1.2 Why do we collect this information?
We use this information to respond to your enquiry, including providing you with any requested information about our services.
2.1.3 What do we do with your information?
Your information and enquiry are stored in our CRM system and processed by the relevant department, depending on the nature of your enquiry. For example, if the enquiry relates to the provision of driving lessons or the provision of access to a RED App it will be passed to the RED Driving School sales team, or to our RED Instructor Training sales team if it relates to training to become a driving instructor.
All our teams are based in the United Kingdom.
We do not use the information you provide to make any automated decisions that might affect you.
2.1.4 If you request a copy of RED’s DRIVE E-zine
We will use your information to send you our E-zine, which contains information about learning to drive and related subjects and often includes special offers.
We ask for your consent to do this, and we will only send you our E-zine once.
2.1.5 If you indicate you are happy to be contacted by RED
We may email, call or contact you via SMS after your initial enquiry or app download in order to follow up on your interest and ensure that we have answered all your queries to your satisfaction. We will do this based on the consent you explicitly provide when you submit your enquiry.
2.1.6 How long do we keep your information for?
When you make an enquiry but do not go on to make a purchase we keep your information as detailed in the table below:
| Enquiry relating to | Information held for |
|---|---|
| Driving Lessons | Up to 30 days from the date of your enquiry |
| Becoming a driving instructor | Up to 3 years from the date of your enquiry |
| Joining RED as an existing ADI or PDI | Up to 3 years from the date of your enquiry |
2.2.1 What personal data do we collect?
When you purchase products from us, we will ask you for some, or all, of the following: your name, address, contact telephone number, email address and date of birth. If you purchase online, we may also record your IP (Internet Protocol) address, which is the address of your computer on the Internet. We will also ask you to enter your payment card details online or over the phone but in both cases no record of this is stored on our systems at any time.
2.2.2 Why do we collect this information?
We require this information to process your payment, deliver your products or services and fulfil our contract with you. We record your IP address for fraud prevention. We will also send you a receipt via email and we may use your telephone number and email address to contact you regarding your purchase.
2.2.3 What do we do with your information?
Your information is stored on our website and on our servers, which are based within the European Union. Your payment card details are sent directly to a third-party payment processor which is based in the EU. We do not receive or retain your credit card details.
We may share your name and email address with Trustpilot (Trustpilot A/S, Pilestraede 58, 5th floor, DK-1112 Copenhagen K) acting as our data processor to invite you to provide a review of the products and services received from RED. Trustpilot will only hold and use your data for this purpose and will store your data for 30 days.
We do not use the information you provide to make any automated decisions that might affect you.
2.2.4 How long do we keep your information for?
We will retain your personal data for as long as you are an active customer plus 6 complete financial years of the company from your last recorded activity.
2.3.1 What personal data do we collect?
When you download and access one of our Mobile Apps, we may store your, name, address, phone number and email address and any additional relevant personal information you may provide us with as needed for the functionality the Mobile App provides.
2.3.2 Why do we collect this information?
We require this information to deliver your products or services and fulfil our contract with you. We may record your IP address for fraud prevention.
2.3.3 What do we do with your information?
Your information is stored on our website and on our servers, which are based within the European Union.
We do not use the information you provide to make any automated decisions that might affect you.
2.3.4 How long do we keep your information for?
We will retain your personal data for as long as you are an active customer plus 6 complete financial years of the company from your last recorded activity.
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
You have the right to ask us to stop using your information at any time or if you believe we are not doing so lawfully.
To submit a request regarding your personal data by email or post, please use the Data Protection Officer contact information provided above in the Who Are We? section of this policy.
If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Information Commissioner’s Office via their website at ico.org.uk/concerns or write to them at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
We regularly review and, if appropriate, update this privacy policy and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.
We will update the version number and date of this document each time it is changed.
Respecting the privacy rights of our customers is very important to us. We are committed to complying with the Data Protection Act 1998 and, when it comes into force, the General Data Protection Regulation 2016/679. This privacy policy explains how we collect, store and use personal data about you when you visit our websites ( https://www.reddrivingschool.com/driver-risk-management/ www.nfegroup.co.uk, www.automotional.com, www.performanceondemand.co.uk,) and our mobile, tablet and other applications (our “Sites”). This policy applies to all our Sites regardless of how they are made available to you or accessed by you.
Please read this privacy policy carefully before you start using our Sites, as this policy will apply to your use of our Sites.
By accessing, browsing and using our Sites, you confirm that you accept this privacy policy. If you do not want your data to be used as set out in this privacy policy, you should not use our Sites. However, you do not have to consent to any of our marketing in order to use our Sites or receive our products. If you have consented to direct marketing but have subsequently changed your mind, please email info@redtraining.com to opt out.
Your use of our Sites, including any orders you place, is governed by our Terms and Conditions of Sale. Please take the time to read these, as they include important terms which apply to you.
WHO ARE WE?
The data controller of our Sites is RED DRM Limited (“we”, “us” or “our”) of (Unit 3a, Western Paddock, Donington Park, Castle Donington, Derbyshire, DE74 2BN). If you have any questions about how we treat your personal data, please contact the Data Protection Officer at RED DRM Head Office, Unit 3a, Western Paddock, Donington Park, Castle Donington, Derbyshire, DE74 2RP or via email to info@redtraining.com.
What information do we collect and why do we collect it?
Using your personal information
Who do we share this information with?
Where do we store your personal data?
How to get copies of or amend the information we have collected
Linking
Passwords
Changes to our Privacy Policy
How to Contact Us
WHAT INFORMATION DO WE COLLECT AND WHY DO WE COLLECT IT?
When you visit our Sites, we may collect:
Information such as your computer’s IP address, browser type and version and anonymous information collected from cookies when you are browsing our Sites. We collect this information to help us understand how to improve our services and our Sites and to ensure that the content on our Sites is presented to you in an effective manner. We have a legitimate business interest for this processing: to ensure that our Site is operating effectively and to provide you with a great service.
Personal information such as your name, address, phone number, date of birth, driving licence number and email address as provided by you when you register to or place an order with us and enter your payment card details. We collect this information for the following reasons:
• To process your order. We engage third party processors to process the payment of your order. We collect this information to perform a contract with you and, if you fail to give us the information that we request, then you may not be able to place an order. If you consent to them doing so, the third party processors (PayPal, Global Payments) may store your payment card details to speed up your transaction time.
• For product development (for example, call backs for feedback on new products), for statistical, market research, testing and survey purposes, to notify you about changes to our Sites or our services. We have a legitimate business interest to collect this information: to continue to improve the services we provide to you;
• To ensure you receive marketing and offers that are of most interest and relevance to you.
• Information that you provide to us when requesting a Quick Quote (including your name, email address, company name (if provided) and contact phone number)
• Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address)
USING YOUR PERSONAL INFORMATION
What have I consented to?
We will not send direct marketing messages to you unless you have opted-in to our marketing. If you have opted-in, this means that we may contact you via email or phone.
• with offers about our products;
• to deliver relevant, tailored advertising to you with information about products or services we feel may interest you.
• Administer our website and business
• Personalise our website for you
• Enable your use of the services available on our website
• Send you information or prices requested
• Send you non-marketing commercial communications
• Send you email notifications that you have specifically requested
• Send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter)
•
Can I withdraw consent?
You are always free to opt-in to our marketing and you are always free to opt-out at anytime; this will never have an impact on our commitment to provide you with great service and a quality product. To withdraw consent to marketing, please click here. We will stop sending you marketing messages as soon as possible but, in any event, will do so no later than 30 days from your request to withdraw consent.
How long do you keep my consent?
We will remove your details from our systems for marketing purposes once your account is closed and destroy any associated papers once our legal/accounting obligation to keep them has expired.
This Section sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the retention and
deletion of personal information. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data; to the extent that we are required to do so by law; if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
Updating your consent
From time to time we may ask you to update your consent to make sure that you are still happy to receive marketing communications. If you are presented with an opt-in box and choose not to receive marketing communication from us on some or all media, we will update our records accordingly.
WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your personal information with a purchaser or a potential purchaser of our business. We have a legitimate business interest to do this: to assist with the sale or potential sale of our business.
We may also share your information with 3rd party service providers in order to facilitate your order or service.
We may disclose your personal information to any of our employees, officers, insurers,
professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary
for the purposes set out in this policy or the services we provide.
We may disclose your personal information to any member of our group of companies
(this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes set out in this policy.
In some circumstances, we may have to disclose your personal information by law, because a court or the police or other legal or regulatory enforcement agency has asked us for it.
We require all third parties that we work with to treat your personal information as confidential and to fully comply with all applicable UK and Ireland data protection and consumer legislation.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) pursuant to: (a) the model clauses published by the European pursuant to Commission Decision C(2010) 593 Standard Contractual Clauses (Processors) and a copy of the model contract clauses is available here; or (b) Where we transfer or store personal data in the United States, the US Privacy Shield Regime. It may also be processed by selected third parties operating outside the EEA engaged in, for example, the processing of your payment details. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Information that we collect will not be transferred outside the European Economic Area
without ensuring that the personal information is protected to an equivalent standard.
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 any data transmitted to our Sites and 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. All information you provide to us is stored on our secure servers. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and corporate policies to safeguard and secure the information we receive.
HOW TO GET COPIES OF OR AMEND THE INFORMATION WE HAVE COLLECTED
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you, please contact us at info@redtraining.com or write to us at RED DRM , Unit 3a, Western Paddock, Donington Park, Castle Donington, Derbyshire, DE74 2RP for the attention of the Data Protection Officer.
If you think any information we have about you is incorrect or incomplete, please write to us or email us and we will correct or update any information as soon as possible.
LINKING
We may link to other websites which are not within our control. Once you have left our Sites, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement applicable to the website in question.
PASSWORDS
You are required to create a password when you register an account with us. Creating a secure password is one of the best ways of keeping your information safe and you can change this at any time by logging into your account.
You should never write your passwords down anywhere, or share them with anyone, including close family members.
Although it may be tempting to use the same password if you have more than one online account on different websites, it is far more secure to have a different and unique password for each online account you have. This reduces the chances of all your accounts being accessed if one of your passwords is compromised.
You should also regularly change your password to improve the security of your online account.
Similarly, if you ever have any suspicions that someone may have accessed your account, you should immediately change your password.
You can re-set your password on our websites any time by logging into your account and selecting the ‘change my password’ option.
If you’ve forgotten your password, enter your email address on the ‘forgotten your password’ page and we’ll send you an email. Simply follow the instructions in the email to change your password.
CHANGES TO OUR PRIVACY POLICY
Any changes we make to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
HOW TO CONTACT US
If you have any questions about our Privacy Policy, please contact the Data Protection Officer RED DRM , Unit 3a, Western Paddock, Donington Park, Castle Donington, Derbyshire, DE74 2BN or via email to info@redtraining.com
Last Updated: 12th September 2023
1. Introduction and General Terms
This privacy policy sets out how we use data relating to you that you provide to us, or that we may collect, through:
– “RED Complete Driving Theory” application (“App”)
– “Learn to Drive with RED” application (“App”).
Together the “Apps”
The Apps are owned and operated by RED Driving School, which is the trading name of RDS Driving Services Limited, a company registered in England and Wales under company number 07372476 and with our registered office at Pavilion 6 Coxwold Way, Belasis Hall Technology Park, Billingham, England, TS23 4EA (“RED”, “we”, “us” or “our”). RDS Driving Services is a subsidiary company of the group of companies headed by Hamilton TOPCO Limited.
We are committed to protecting and respecting your privacy. This policy explains what personal information we collect from you and how that information will be processed. Where we decide the purpose or means for which personal data you supply through these online services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
This policy explains the following
The Apps may contain hyperlinks to websites owned and operated by third parties. They will govern the use of personal information you submit, or which is collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of them is at your own risk.
2. Information we may collect about you
We collect and process the following information which may include your personal data.
Submitted Information
You may give us information about you by filling in forms when using our services and when creating your account during registration.
This can include:
We may also obtain sensitive personal data about you if you voluntarily supply it through the App. For example, when you communicate with us via the contact page on the Website or via e-mail.
How you use our Apps/Website (“Analytics”)
We may collect technical information about your computer and/or device that may identify you, including your IP address, operating system, browser type, time-zone, and browser plug-in details through third party analytics providers. These third-party analytics providers may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notice.
Information about you collected from Third Parties (“Content Information”)
We may collect information about you from third-party service providers (like marketing partners or public databases) to use along with the information we collect from you.
Other companies may set their own cookies or similar technologies when you use the Apps and/or visit the Website. This includes third parties that we have engaged to provide services on our behalf (like website analytics), as well as third parties that deliver content (like videos from YouTube).
3. Why we collect information about you
To provide the Apps/Website
We will use information about you for providing the Apps and/or Website and delivering our services to you.
To Understand how our Website/Apps is used
We process information to understand how visitors use our Apps and/or Website. This processing is necessary for us to pursue our legitimate interest of
4. Data sharing
We will share your information with third parties only in the ways described in this privacy policy. If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.
Personnel, other Hamilton TOPCO owned subsidiary companies, Suppliers or Subcontractors: We keep your information confidential but may disclose it to our personnel, suppliers, or subcontractors as far as it is necessary for the purposes set out in this privacy policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard this information
Personnel, other Hamilton TOPCO owned subsidiary companies, Suppliers or Subcontractors: We keep your information confidential but may disclose it to our personnel, suppliers, or subcontractors as far as it is necessary for the purposes set out in this privacy policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard this information
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties to enforce or apply the terms of agreements, investigate potential breaches, or protect our rights, property, or safety or those of our customers or others.
5. Data retention
We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected.
6. Your rights in relation to personal data which we process relating to you
You have the right to access, modify, rectify, and delete any data that concerns you over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let us know via the Website.
If you do provide us with personal information, we retain it for as long as your account on the Website and/or Apps are active, or as is otherwise necessary for us to provide the Website and/or Apps to you, or as otherwise described in this privacy policy.
7. Children
You should be at least 16 to use our Apps and register an account on the Apps. We do not use the Apps to knowingly solicit data from or market to children under the age of 16. If a parent or guardian becomes aware that their child has given us information without their consent, they should contact us via the contact details detailed at the top of this privacy policy. We will delete such information from our files within a reasonable time.
8. Security
We will take reasonable physical, technical, and organisational precautions to protect your personal information from unauthorised access, use or disclosure. For example, we use computer systems with limited access in controlled facilities to store personal info. We also use technologies like encryption and hashing to protect some of the information we collect.
Please be aware that, although we endeavour to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches. By choosing to share your personal information with us you agree and accept that you do so at your own risk.
9. International data transfers
Where we transfer your data outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you want to learn more about these safeguards, please tell us by writing to us through the Support Services [WHERE?].
10. Cookies
A cookie is a text file placed onto your device when you access the Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor the Website, including in the following ways:
Authentication
To log you into your account on the Website and keep you logged in.
Preferences
To remember information about you such as your preferred language and configuration.
Analytics
To help us understand how you use the Website, and how often, so we can improve it to deliver a better experience for our users.
The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.
Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of the Website.
11. Changes
We may make changes to this policy, and such changes will be posted on this page. You should check this page occasionally to ensure you are aware of any changes. Where appropriate we may notify you of any changes by email.
