1. Who are we and introduction
1.1 We are Handsfree Group and we pride ourselves on years of experience working with transport, logistics, fleet and emergency services providers providing equipment and technology to help their employees drive, communicate and promote safe
1.2 Handsfree Group is made up of Handsfree Group Ltd in England and Wales and Fleet Installation Ltd trading as Handsfree Group in the Republic Ireland. We also have offices in the United States of America. For more details on our Group structure and to contact us see section link to section 12 below.
We are committed to safeguarding the privacy of our website visitors, service users and customers. In this policy we explain how we will handle your personal data.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
2.3 We process your account data (“account data“). The account data includes your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
2.4 We process personal information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
2.5 We process your personal data that are provided in the course of the use of our services (“service data“). The service data may include Datalive credentials. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
2.6 We process personal information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). If you have made an enquiry about our products and/ or services, we may contact you for the purposes of responding to your enquiry. Our legal basis for this is that it is necessary to take such steps at your request prior to entering into a contract with you. We may also use your details to tell you and/ or your company about our products and services we feel you may be interested in. For more information about your rights in relation to this, please see section 3 Using your personal data for marketing purposes below.
2.7 We process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business, provided they are not outweighed by your rights as an individual.
2.8 We process information that you provide to us for the purpose of subscribing to our newsletters (“notification data“) for the purposes of sending you our or newsletter. The legal basis for this processing is consent. For more information about your rights in relation to this, please see section 3 Using your personal data for marketing purposes below.
2.9 We process personal information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data typically includes the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users, provided they are not outweighed by your rights as an individual.
2.10 We process personal information that we collect from third parties when we procure information from third parties (including Data Ireland) for business to business direct email marketing. The legal basis for this processing is that it is in our legitimate interests to promote our business and products provided that our doing so is not outweighed by your rights as an individual. For more information about your rights in relation to this, please see section 3 Using your personal data for marketing purposes below.
2.11 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others, provided they are not outweighed by your rights as an individual.
2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Sharing your personal data
We share your personal data with the parties set out below for the purposes set out in this notice.
- Service providers (acting as processors) who provide IT and system administration services and support.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
- Legal or taxation authorities or regulators and other authorities based in the United Kingdom.
- Third parties in connection with legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal rights.
- 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 notice.
We require all third party processors 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. Our legal basis for this processing is either that it is in our legitimate interests to do so and your interests as an individual do not override those interests, or because we are subject to a legal obligation to do so.
- Using your personal data for marketing purposes – important information about your rights.
4.1 If you have enquired about our products and/or services, signed up to our newsletter or if we have procured your details from a third party we use such data to send you details, business to business (including by email) of our products and/ or services that we feel you or your company may be interested in.
4.2 Our legal bases for doing so are set out for each case in section 2 How we process your personal data above.
4.3 However we have obtained your personal data for marketing purposes, you can object to our use of your personal data for direct marketing (or withdraw your consent to such communications if appropriate) at any time by either following the instructions in the relevant communication or by contacting us via email: [email protected] or post Handsfree Group, 6 Lumsdale Road, Cobra Court, Trafford Park, Manchester, M32 0UT.
- International transfers of your personal data
5.1 We do not transfer your personal data to countries outside of the European Economic Area.
- Retaining and deleting personal data
5.1 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 data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes and for the purpose of satisfying any legal, accounting or reporting requirements that apply to us, or in order to protect your vital interests or somebody else’s. When determining how long to keep your personal data for we consider the amount, nature and sensitivity of that personal information and the potential risk of harm from its unauthorised use or disclosure.
5.3 If you are a website user we will retain and delete your personal data for 2 years following a user’s visit, at the end of which period it will be deleted from our systems;
For more information about how long we retain personal data for please contact us using the details set out in section 12.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy
- Your rights
7.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw your consent, where we are processing your personal data on the basis of having your consent to do so.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can attain a copy by emailing us at the address given below in section 12.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; or the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK, the data protection authority is the Information Commission, who can be contacted through https://ico.org.uk. In Ireland, the data protection authority is the Data Protection Commission, which can be contacted on https://www.dataprotection.ie.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8.
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- Our details
This website is owned and operated by The Handsfree Group..
In the UK:
Handsfree Group LTD, incorporated in England and Wales with company number 05519584, registered address: 6 Lumsdale Road, Cobra Court, Stretford, Manchester M32 0UT.
In the Republic of Ireland
Fleet Installation Limited trading as Handsfree Group, incorporated in Ireland with company number 646486, registered address: BCA Chartered Accountants, Clonminch Hi-Technology Park, Clonminch, Tullamore, Co Offaly.