Privacy Policy
Consent to installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details and device information).
YES I consent to the installation of the App for the purposes of [PURPOSE OF APP].
NO I do not consent to the installation of the App.
How you can withdraw consent
Once you provide consent by selecting"YES", you may change your mind and withdraw consent at any time bycontacting us [CONTACT DETAILS] but that will not affect the lawfulness of anyprocessing carried out before you withdraw your consent.
Consent to processing Location Data
YES I consent to processing of my Location Data([including details of my current location disclosed by GPS technology so thatlocation-enabled Services are activated [to [PURPOSE OF LOCATION-ENABLED SERVICES]]).
NO I do not consent to processing of my Location Dataand location-enabled Services are disabled in my settings.
CARWOOSHH LIMITED (we) are committed to protecting your personal data andrespecting your privacy.
This policy (together with ourend-user licence agreement as set out at [WEB ADDRESS OF EULA] (EULA) and any additional terms of use incorporated byreference into the EULA, together our Terms of Use)applies to your use of:
· [NAME AND VERSION OF APP] mobile applicationsoftware (App) available on our site OR hosted on [X] (AppSite), once you have downloaded or streamed a copy of the App onto yourdevice (Device).
· Any of the services accessible through the App (Services) that are available on the App Site or othersites of ours (Services Sites). This policy sets outthe basis on which any personal data we collect from you, or that you provideto us, will be processed by us. This App is not intended for children and we donot knowingly collect data relating to children. Please read the followingcarefully to understand our practices regarding your personal data and how wewill treat it.
Importantinformation and who we are
CARWOOSHH LIMITED is the controllerand is responsible for your personal data (collectively referred to as"Company", "we", "us" or "our" in thispolicy).
Contact details
Our full details are:
· Full name of legal entity: CARWOOSHH LIMITED
· Name or title of [DPO OR data privacy manager]:
· Email address: [DETAILS]
· Postal address: [DETAILS]
· [Telephone number: [DETAILS]]
You have the right to make acomplaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy underregular review.
This version was last updated on[DATE]. It may change and if it does, these changes will be posted on this pageand, where appropriate, notified to you when you next start the App or log ontoone of the Services Sites. The new policy may be displayed on-screen and youmay be required to read and accept the changes to continue your use of the Appor the Services.
It is important that the personaldata we hold about you is accurate and current. Please keep us informed if yourpersonal data changes during our relationship with you.
Third party links
Our Sites may, from time to time,contain links to and from the websites of our partner networks, advertisers andaffiliates. Please note that these websites and any services that may beaccessible through them have their own privacy policies and that we do notaccept any responsibility or liability for these policies or for any personaldata that may be collected through these websites or services, such as Contactand Location Data. Please check these policies before you submit any personal datato these websites or use these services.
We may collect, use, store andtransfer different kinds of personal data about you as follows:
· Identity Data.
· Contact Data.
· Financial Data.
· Transaction Data.
· Device Data.
· Content Data.
· Profile Data.
· Usage Data.
· Marketing and Communications Data.
· Location Data
We also collect, use and shareAggregated Data such as statistical or demographic data for any purpose.Aggregated Data could be derived from your personal data but is not consideredpersonal data in law as this data will not directly or indirectly reveal youridentity. For example, we may aggregate your Usage Data to calculate the percentageof users accessing a specific App feature. However, if we combine or connectAggregated Data with your personal data so that it can directly or indirectlyidentify you, we treat the combined data as personal data which will be used inaccordance with this privacy policy.
We do not collect any SpecialCategories of Personal Data about you (this includes details about your race orethnicity, religious or philosophical beliefs, sex life, sexual orientation,political opinions, trade union membership, information about your health, andgenetic and biometric data). Nor do we collect any information about criminalconvictions and offences.
How is yourpersonal data collected?
We will collect and process thefollowing data about you:
· Informationyou give us. This is information (including Identity, Contact and Marketingand Communications Data) you consent to giving us about you by filling in formson the App Site and the Services Sites (together Our Sites),or by corresponding with us (for example, by email or chat). It includesinformation you provide when you register to use the App Site, download orregister an App, subscribe to any of our Services, search for an App orService, [make an in-App purchase,] [share data via an App's social mediafunctions,] [enter a competition, promotion or survey,] [or] [OTHER ACTIVITIESCOMMONLY CARRIED OUT IN CONNECTION WITH AN APP] and when you report a problemwith an App, our Services, or any of Our Sites. If you contact us, we will keepa record of that correspondence.
· Informationwe collect about you and your device. Each time you visit one of Our Sitesor use one of our Apps we will automatically collect personal data includingDevice, Content and Usage Data. We collect this data using cookies and othersimilar technologies. Please see our cookie policy [LINK] for further details.
· LocationData. We also use [GPS technology OR[OTHER TECHNOLOGY]] to determine your current location. Some of ourlocation-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 yourdata being used for this purpose. You can withdraw your consent at any time by[disabling Location Data in your settings OR[OTHER WAY IN WHICH CONSENT CAN BE WITHDRAWN]].]
· Informationwe receive from other sources including third parties and publicly availablesources. We will receive personal data about you from various third partiesand public sources as set out below [DELETE OR ADD TO THIS LIST ASAPPROPRIATE]:
· Device Data from the following parties:
analytics providers [such as Googlebased outside the UK];
advertising networks [such as[NAME] based [inside OR outside] theUK]; and
search information providers [suchas [NAME] based [inside OR outside]the UK].
· Contact, Financial and Transaction Data fromproviders of technical, payment and delivery services [such as [NAME] based[inside OR outside] the UK];
· [ANY OTHER WAYS YOU COLLECT PERSONAL DATA].
We use cookies and/or othertracking technologies to distinguish you from other users of the App, App Site,the distribution platform (Appstore) or Services Sites and to remember yourpreferences. This helps us to provide you with a good experience when you usethe App or browse any of Our Sites and also allows us to improve the App andOur Sites. For detailed information on the cookies we use, the purposes forwhich we use them and how you can exercise your choices regarding our use ofyour cookies, see our cookie policy [LINK].
We will only use your personal datawhen the law allows us to do so. Most commonly we will use your personal datain the following circumstances:
· Where you have consented before the processing.
· Where we need to perform a contract we are aboutto enter or have entered with you.
· Where it is necessary for our legitimateinterests (or those of a third party) and your interests and fundamental rightsdo not override those interests.
· Where we need to comply with a legal orregulatory obligation.
We will only send you directmarketing communications by email or text if we have your consent. You have theright to withdraw that consent at any time by contacting us.
Purposes forwhich we will use your personal data
Purpose/activity
Type of data
Lawful basis for processing
To install the App and register you as a new App user
Identity
Contact
Financial
Device
Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services
Identity
Contact
Financial
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey
Identity
Contact
Device
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Consent
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosuresof your personal data
When you consent to providing uswith your personal data, we will also ask you for your consent to share yourpersonal data with the third parties.
We do not transfer your personaldata outside the UK.
All information you provide to usis stored on our secure servers. Any payment transactions carried out by us orour chosen third-party provider of payment processing services will beencrypted using [Secured Sockets Layer technology OR [ALTERNATIVE ENCRYPTION TECHNOLOGY]]. Where we have given you(or where you have chosen) a password that enables you to access certain partsof Our Sites, you are responsible for keeping this password confidential. Weask you not to share a password with anyone.
Once we have received yourinformation, we will use strict procedures and security features to try toprevent your personal data from being accidentally lost, used or accessed in anunauthorised way.
We have put in place procedures todeal with any suspected personal data breach and will notify you and anyapplicable regulator when we are legally required to do so.
By law we have to keep basicinformation about our customers (including Contact, Identity, Financial andTransaction Data) for 6 years after they cease being customers for taxpurposes.
In some circumstances you can askus to delete your data: see below for further information.
In some circumstances we willanonymise your personal data (so that it can no longer be associated with you)for research or statistical purposes, in which case we may use this informationindefinitely without further notice to you.
In the event that you do not usethe App for a period of [TIME PERIOD] then we will treat the account as expiredand your personal data may be deleted.
Under certain circumstances youhave the following rights under data protection laws in relation to yourpersonal data.
You also have the right to ask usnot to continue to process your personal data for marketing purposes.
You can exercise any of these rightsat any time by contacting us at [EMAIL ADDRESS].
Consentmeans processing your personal data where you have signified your agreement bya statement or clear opt-in to processing for a specific purpose. Consent willonly be valid if it is a freely given, specific, informed and unambiguousindication of what you want. You can withdraw your consent at any time bycontacting us.
LegitimateInterest means the interest of our business in conducting and managingour business to enable us to give you the best service/product and the best andmost secure experience. We make sure we consider and balance any potentialimpact on you (both positive and negative) and your rights before we processyour personal data for our legitimate interests. We do not use your personaldata for activities where our interests are overridden by the impact on you(unless we have your consent or are otherwise required or permitted to by law).You can obtain further information about how we assess our legitimate interestsagainst any potential impact on you in respect of specific activities bycontacting us.
Performanceof Contract means processing your data where it is necessary for theperformance of a contract to which you are a party or to take steps at your requestbefore entering into such a contract.
Comply witha legal obligation means processing your personal data where it isnecessary for compliance with a legal obligation that we are subject to.
Other companies in the CarwooshhLimited Group [acting as joint controllers or processors] and who are based in[SPECIFIC COUNTRIES] and provide [IT and system administration services andundertake leadership reporting].
Service providers [acting asprocessors] based in [SPECIFIC COUNTRIES] who provide [IT and systemadministration services].
Professional advisers acting asprocessors including lawyers, bankers, auditors and insurers who provideconsultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs,regulators and other authorities acting as processors based in the UK whorequire reporting of processing activities in certain circumstances.
You have the right to:
· Requestaccess to your personal data (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the personal data we holdabout you and to check that we are lawfully processing it.
· Requestcorrection of the personal data that we hold about you. This enables you tohave any incomplete or inaccurate data we hold about you corrected, though wemay need to verify the accuracy of the new data you provide to us.
· Requesterasure of your personal data. This enables you to ask us to delete orremove personal data where there is no good reason for us continuing to processit. You also have the right to ask us to delete or remove your personal datawhere you have successfully exercised your right to object to processing (seebelow), where we may have processed your information unlawfully or where we arerequired to erase your personal data to comply with local law. Note, however,that we may not always be able to comply with your request of erasure forspecific legal reasons which will be notified to you, if applicable, at the timeof your request.
· Object toprocessing of your personal data where we are relying on a legitimateinterest (or those of a third party) and there is something about yourparticular situation which makes you want to object to processing on thisground as you feel it impacts on your fundamental rights and freedoms. You alsohave the right to object where we are processing your personal data for directmarketing purposes. In some cases, we may demonstrate that we have compellinglegitimate grounds to process your information which override your rights andfreedoms.
· Requestrestriction of processing of your personal data. This enables you to ask usto suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you donot want us to erase it;
· Requestthe transfer of your personal data to you or to a third party. We willprovide to you, or a third party you have chosen, your personal data in astructured, commonly used, machine-readable format. Note that this right onlyapplies to automated information which you initially provided consent for us touse or where we used the information to perform a contract with you.
· Withdrawconsent at any time where we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processingcarried out before you withdraw your consent. If you withdraw your consent, wemay not be able to provide certain products or services to you. We will adviseyou if this is the case at the time you withdraw your consent.
Descriptionof categories of personal data
· IdentityData: first name, last name, maiden name, username or similar identifier,marital status, title, date of birth, gender.
· ContactData: billing address, delivery address, email address and telephonenumbers.
· FinancialData: bank account and payment card details.
· TransactionData: includes details about payments to and from you and details of in-Apppurchases.
· DeviceData: includes the type of mobile device you use, a unique deviceidentifier (for example, your Device's IMEI number, the MAC address of theDevice's wireless network interface, or the mobile phone number used by theDevice), mobile network information, your mobile operating system, the type ofmobile browser you use, [time zone setting, [OTHER INFORMATION].
· ContentData: includes information stored on your Device, including logininformation, [photos, videos or other digital content,] [OTHER INFORMATION].
· ProfileData: includes your username and password, in-App purchase history, yourinterests, preferences, feedback and survey responses.
· UsageData: includes details of your use of any of our Apps or your visits to anyof Our Sites including, but not limited to, [traffic data [and othercommunication data],] whether this is required for our own billing purposes orotherwise.
· Marketingand Communications Data: includes your preferences in receiving marketingfrom us and our third parties and your communication preferences.
· LocationData: includes [your current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]].
Cookie Policy
Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our website. This policy should be read together with our [Website Privacy Policy] which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.
Who we are
This website is operated by XXXX. We are CARWOOSHH LIMITED for more information see XXX.
Our website
This cookie policy relates to your useof our website, www.carwooshh.com.
Cookies
A cookie is a small text file which isplaced onto your device (eg computer, smartphone or other electronic device)when you use our website. We use cookies on our website.
Cookies are either:
Session cookies: these are only storedon your computer during your web session and are automatically deleted when youclose your browser – they usually store an anonymous session ID allowing you tobrowse a website without having to log in to each page but they do not collectany personal data from your computer; or
Persistent cookies: a persistent cookieis stored as a file on your computer and it remains there when you close yourweb browser. The cookie can be read by the website that created it when youvisit that website again. We use persistent cookies for Google Analytics.
Cookies can also becategorised as follows:
Strictly necessarycookies:These cookies are essential to enable you to use the website effectively, suchas when buying a product and / or service. Without these cookies, the servicesavailable to you on our website cannot be provided. These cookies do not gatherinformation about you that could be used for marketing or remembering where youhave been on the internet.
Performance cookies: These cookies enableus to monitor and improve the performance of our website. For example, theyallow us to count visits, identify traffic sources and see which parts of thesite are most popular.
Functionality cookies: These cookies allowour website to remember choices you make and provide enhanced features. Forinstance, we may be able to provide you with news or updates relevant to theservices you use. They may also be used to provide services you have requestedsuch as viewing a video or commenting on a blog. The information these cookiescollect is usually anonymised.
Targeting cookies: These cookies recordyour visit to our website, the pages you have visited and the links you havefollowed. We will use this information to make our website and the advertisingdisplayed on it more relevant to your interests.
First and third party cookies: First party cookies are cookies set by our website. Third party cookies are cookies on our website that are set by a website other than our website, such as where we have adverts on our website or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.
Consent to use cookies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Type
Cookie Description
Duration[MPJ1]
How to turn off all cookies and consequences of doing so
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
For further information about cookies and how to disable them please go to the guidance on cookies published by the UKInformation Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
How to contact us
Please contact us if you have any questions about this cookie policy or the information we hold about you.
Changes to this policy
This policy was published on [insertdate]. We may change this policy from time to time.
[MPJ1]Wewill need to include the details from your cookie report within this table.
