Privacy policy
1. Important information and who we are
Purpose of this privacy policy
This privacy policy gives you information about how Spare Seat
collects and uses your personal data through your use of our
website and platform (Website), including any data you may provide
when you register with us, offer or request a journey via the
Website.
Controller
DRMSITE LTD (company number 17151917, whose registered office is
at 40 Elm Close, Witchford, Ely, CB6 2JH) is the controller and
responsible for your personal data (collectively referred to as
“Spare Seat”, "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any
requests to exercise your legal rights (section 9), please contact
us using the contact details set out in section 10.
2. The types of personal data we collect about you
Personal data means any information about an individual from which
that person can be identified.
We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together as follows:
-
Identity Data
includes first name, last name, and a profile photo (if you
choose to upload one).
-
Contact Data
includes email address and telephone numbers.
-
Ride Data
includes departure/destination locations, dates and times, seat
availability, any notes added when posting a ride and any
messages with riders when arranging a ride.
-
Request Data
includes messages and other details submitted when requesting a
seat.
-
Technical Data
includes internet protocol (IP) address, your login data,
browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and
platform, device ID and other technology on the devices you use
to access the Website.
-
Usage Data
includes information about how you interact with and use our
Website.
-
Profile Data
includes your username and password, requests or listings made
by you, your preferences, and any feedback.
We also collect, use and share aggregated data such as statistical
or demographic data which is not personal data as it does not
directly (or indirectly) reveal your identity. For example, we may
aggregate individuals’ Usage Data to calculate the percentage of
users accessing a specific Website feature in order to analyse
general trends in how users are interacting with our Website to
help improve the Website, and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you
including through:
-
Your interactions with us.
You may give us your personal data by using our Website, filling
in online forms or by corresponding with us by post, phone,
email or otherwise. This includes personal data you provide when
you:
- offer or request a journey via our Website;
- create an account on our Website; or
- give us feedback or contact us.
-
Automated technologies or interactions.
As you interact with our Website, we will automatically collect
Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies and
other similar technologies. Please see our
cookie policy
for further details.
-
Third parties or publicly available sources.
We will receive personal data about you from various third
parties. For example, Technical Data is collected from analytics
providers such as Google based outside the UK.
-
Signing in with Google.
You may choose to create an account or log in using your Google
account. If you do so, Google will provide us with certain
information associated with your Google account, which may
include your name, email address, profile picture and unique
Google account identifier. We use this information to create and
manage your account, authenticate your identity, provide our
services, and maintain the security of our platform. We do not
receive or store your Google account password. The information
we receive depends on the permissions you grant when using
Google's authentication service. You can revoke access at any
time through your Google account settings but you may also lose
access to your account on our Website. For more information
about how Google processes your personal information, please see
Google's Privacy Policy.
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using
your personal data. We rely on one or more of the following legal
bases:
-
Performance of a contract with you:
Where we need to perform the contract we are about to enter into
or have entered into with you.
-
Legitimate interests:
We may use your personal data where it is necessary to conduct
our business and pursue our legitimate interests, for example to
prevent fraud and enable us to give you the best and most secure
customer experience. We make sure we consider and balance any
potential impact on you and your rights (both positive and
negative) before we process your personal data for our
legitimate interests. We do not use your personal data 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).
-
Legal obligation:
We may use your personal data where it is necessary for
compliance with a legal obligation that we are subject to. We
will identify the relevant legal obligation when we rely on this
legal basis.
-
Consent:
We rely on consent only where we have obtained your active
agreement to use your personal data for a specified purpose, for
example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the
ways we plan to use the various categories of your personal data,
and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
How we use your personal data
| Purpose/Use |
Type of data |
Legal basis |
| To create and manage accounts |
(a) Identity (b) Contact (c) Profile |
(a) Performance of a contract with you (b) Necessary for
our legitimate interests
|
| To enable users to post, view and arrange rides |
(a) Identity (b) Contact (c) Profile (d) Ride (e)
Request
|
(a) Performance of a contract with you (b) Necessary for
our legitimate interests (to recover debts due to us, if
any)
|
To manage our relationship with you which will include: (a)
Notifying you about changes to our terms or privacy policy (b)
Dealing with your requests, complaints and queries
|
(a) Identity (b) Contact (c) Profile (d) Marketing
and Communications
|
(a) Performance of a contract with you (b) Necessary to
comply with a legal obligation (c) Necessary for our
legitimate interests (to keep our records updated and manage
our relationship with you)
|
|
To administer and protect our business and the Website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services,
network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise) (b)
Necessary to comply with a legal obligation
|
| To deliver relevant Website content to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e)
Marketing and Communications (f) Technical
|
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, and to
grow our business)
|
|
To use data analytics to improve our Website,
products/services, customer relationships and experiences
|
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our Website
updated and relevant, and to develop our business)
|
Direct marketing
We do not carry out any direct marketing activities.
Third-party marketing
We will get your express consent before we share your personal
data with any third party for their own direct marketing purposes.
Cookies
For more information about the cookies we use and how to change
your cookie preferences, please see our
cookie policy.
5. Disclosures of your personal data
We may share your personal data where necessary with third parties
who provide services to us such as Firebase (Google) for hosting
and storage purposes and Brevo (Sendinblue SAS) for email
notifications.
We may also share your personal data where necessary to third
parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire
other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the
same way as set out in this privacy policy.
We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do
not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our
instructions.
6. International transfers
We may transfer your personal data to service providers that carry
out certain functions on our behalf. This may involve transferring
personal data outside the UK to countries which have laws that do
not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service
providers, we ensure a similar degree of protection is afforded to
it by ensuring that the appropriate safeguards are in place, such
as:
-
only transferring your personal data to countries that have been
deemed by the UK to provide an adequate level of protection for
personal data; or
-
using specific standard contractual terms approved for use in
the UK which give the transferred personal data the same
protection as it has in the UK, namely the International Data
Transfer Agreement or the International Data Transfer Addendum
to the European Commission’s standard contractual clauses for
international data transfers.
7. Data security
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents,
contractors and other third parties who have a business need to
know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements.
In particular:
-
Ride and Request Data is automatically deleted 48 hours after
the scheduled journey time to minimise the amount of personal
data held on the platform.
-
Personal data directly contained in and forming part of your
Spare Seat account (including names, email address, telephone
number and profile photo) is retained for as long as you
maintain an active account. You may delete your account at any
time, at which point any such account data will be deleted.
-
Personal data contained in and forming part of any archived
journey summaries stored within your Spare Seat account is also
retained only for as long as your account remains active. All
such data will be deleted upon deletion of your account.
In some circumstances, we may retain your personal data for a
longer period such as in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to
our relationship with you.
To determine the appropriate retention period for personal data,
we consider the amount, nature and sensitivity of the personal
data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those
purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see
section 9 below for further information.
9. Your legal rights
You have a number of rights under data protection laws in relation
to your personal data.
You have the right to:
-
Request access
to your personal data (commonly known as a "subject access
request"). This enables you to receive a copy of the personal
data we hold about you and to check that we are lawfully
processing it. Please note that you can download a copy of
certain personal data in machine-readable JSON format directly
from the
My Rides
page (in your profile section) without making a subject access
request.
-
Request correction
of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new
data you provide to us. You can update certain personal data
(such as your name, telephone number and profile photo) directly
within your Spare Seat account.
-
Request erasure
of your personal data in certain circumstances.
-
This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process
it. You may delete your Spare Seat account at any time,
which will result in the deletion of certain personal data
associated with that account (as set out in section 8 “Data
Retention” above).
-
You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your
right to object to processing (see below), where we may have
processed your information unlawfully or where we are
required 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 for specific legal reasons
which will be notified to you, if applicable, at the time of
your request.
-
Object to processing
of your personal data where we are relying on a legitimate
interest (or those of a third party) as the legal basis for that
particular use of your data (including carrying out profiling
based on our legitimate interests). In some cases, we may
demonstrate that we have compelling legitimate grounds to
process your information which override your right to object.
-
Request the transfer
of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal
data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which
you initially provided consent for us to use or where we used
the information to perform a contract with you.
-
Request restriction of processing
of your personal data. This enables you to ask us to suspend the
processing of your personal data in one of the following
scenarios:
- If you want us to establish the data’s accuracy;
-
Where our use of the data is unlawful but you do not want us
to erase it;
-
Where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend
legal claims; or
-
You have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use
it.
If you wish to exercise any of the rights set out above, please
contact us using the contact details set out in section 10.
No fee usually required
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
What we may need from you
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to
any person who has no right to receive it. We may also contact you
to ask you for further information in relation to your request to
speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request
is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
10. Contact details
If you have any questions about this privacy policy or about the
use of your personal data or you want to exercise your privacy
rights, please contact us at
annoyingmouse+spareseat@drmsite.com.
11. Complaints
You have the right to make a complaint to the Information
Commissioner’s Office (ICO), the UK regulator for data protection
issues (www.ico.org.uk). However, before doing so please make sure you have first made
your complaint to us or asked us for clarification if there is
something you do not understand. The ICO will expect you to have
done this before reviewing your complaint.
12. Changes to the privacy policy and your duty to inform us of
changes
We keep our privacy policy under regular review. It is important
that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your
relationship with us, for example a new address or email address.
13. Third-party links
This Website may include links to third-party websites, plug-ins
and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our
Website, we encourage you to read the privacy policy of every
website you visit.