Our Collection Statement
2. Personal Information
2.1 "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
3. What Personal Information do we collect and hold?
3.1 The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with that person. Personal Information that we collect may include (but is not limited to) the following:
(b) age and/or date of birth
(c) contact details including address, email and telephone numbers (landline and/or mobile)
(d) travel information such as intended travel dates, place of departure and intended destination and any special travel arrangements
(e) current address (including postal address)
(f) email address
(h) concession card details (eg type and ID number)
(i) identification information such as driving licence number and driving licence details
(j) payment details, such as your credit card or bank account details
(k) occupation and employment details including employment status and any previous work experience
(l) information from or in connection with your resume or job application if you apply for a position with us
(m) driving history reports
(n) medical information from a pre employment medical check, such as drug and alcohol test results
(o) footage and/or images of you from the security surveillance cameras at our premises
(p) voice recordings of calls to and from you
(q) the type of device you use when accessing the our Wi-Fi Service, the time you access the our Wi-Fi Service, the amount of data you download, your IP address and your media access control address
(r) credit history
(s) financial information including your company number and VAT
(t) trade references, credit references or reports from a third party, and
(u) credit information.
3.2 We collect and record Personal Information about individuals such as:
(a) our customers, potential customers and their representatives
(b) persons enquiring about our fleet vehicles for sale
(c) persons visiting our premises
(d) our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders
(e) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us
(f) our employees past and present, including applicants, and
(g) any other person who comes into contact with us.
4. How and when do we collect Personal Information?
4.1 We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law.
4.2 We may collect your Personal Information in the course of providing you with goods or services, and:
(a) when you use or buy our products or services, including when you submit a booking request, amend a booking request, confirm your identity when you travel, or join our loyalty club
(b) when you provide us, or you offer or apply to supply us, with goods or services
(c) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email)
(d) when you request information about us, our products or our services, including inquiring about our fleet sales
(e) when you provide feedback or make a complaint to us
(f) when you visit or fill in a form on our Website (see paragraph 5)
(g) when you visit premises from which we operate
(h) when you (or your employer) provide information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations
(i) when you access or use the our Wi-Fi Service
(j) when you make a credit application
(k) when you submit a job application to us
(l) when you otherwise contact us by telephone, fax, email, social media, post or in person, or
(m) where we are otherwise required or authorised by law to do so.
4.3 Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect personal information directly from the relevant individual where reasonable and practicable.
4.4 We may also collect Personal Information about you from third parties and other sources such as:
(a) your nominated representatives (eg referee, spouse, accountant, power of attorney, brokers and other professional advisors)
(b) publicly available sources of information (eg searches of publicly available company registers, or social media accounts or posts which are visible to the public), or
(c) related entities, companies and businesses of us,
but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
4.5 If the Personal Information we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.
4.6 Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
5. Information collected via our Website
5.1 Personal information may be collected by us and by our third party service providers who assist us in operating our website at www.thecoachcompany.co.uk, including its subdomains and any other website we operate from time to time (collectively the Website).
5.2 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph 5.
5.3 We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.
5.4 If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
5.5 When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, device hardware and software information, and any information downloaded. This information is used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.
5.6 Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website, including to optimise and personalise website workflow and content.
5.7 Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.
5.8 Cookies may also be used for other purposes, such as to securely store customer membership information to aid in the login process.
5.9 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
5.11 Web beacons are images that originate from a third party site to track visitor activities. From time to time, we may use third party email software to communication with our members, and such software may use web beacons to track information such as the email open rates for individuals that receive promotional offers and service related announcements via email.
5.12 Some of the content on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.
6. How do we use your Personal Information?
6.1 We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers.
6.2 We may collect, hold and use your personal information:
(a) to identify and communicate with you, including to communicate service related announcements via email or text message
(b) to enable us to provide you with requested information, products or services
(c) to process your booking request and amend your booking request, if required
(d) to confirm your identity when you travel
(e) to otherwise assist customers by providing them with information and support
(f) to collect and process payments and provide confirmations or tax invoices in respect of your booking
(g) to help us to manage and enhance products or services we provide to you
(h) to provide you with access to the our Wi-Fi Service
(i) to help us to manage and enhance goods and services we procure from our suppliers and subcontractors
(j) to manage and administer any account you may hold with us
(k) to manage and maintain credit accounts for the provision of goods or services on credit
(l) to carry out credit checks and credit reporting where you or your business are seeking to use a credit facility
(m) to carry out debt and equipment recovery functions
(n) to promote and market our products and services to you, including to correspond with you in relation to our special offers from time to time
(o) to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners
(p) to help us research the needs of our customers to enable us to improve and market our products and services with a better understanding of your needs and the needs of customers generally
(q) to notify and assess insurance claims, pay settlements and finalise claims and determine liability
(r) to provide for the safety and security of workers and onsite visitors
(s) to help us manage our business operations
(t) for business support purposes including maintenance, backup and audit
(u) to process any job application submitted by you and to retain any job application for future vacancies, unless you request us not to
(v) to respond to any feedback, queries or complaints you may have, or
(w) to comply with our statutory and legal obligations.
6.3 We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.
6.5 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
(b) required or authorised by law
7. When do we disclose your Personal Information?
7.1 We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
7.2 We may also disclose your Personal Information to:
(a) any of our internal divisions, business units, offices, depots or departments
(b) your nominated representatives
(c) other organisations or individuals who assist us in providing products and services to you, including contractors performing or providing travel services on behalf of us
(d) professional service providers and advisors who perform functions on our behalf, such as lawyers and our insurers
(e) medical providers including medical and rehabilitation practitioners for assessing insurance claims
(f) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
(g) our mercantile agents and debt collecting agencies
(h) other entities who are your credit providers or trade suppliers, and
(i) Government, regulatory authorities and other organisations as required or authorised by law (such as the Police).
7.3 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
8. Overseas disclosures
8.1 Generally, we do not send or disclose your Personal Information to overseas recipients.
(a) our offices or related entities are overseas
(b) we outsource certain activities overseas
(c) transactions, information, services or products have an overseas connection, or
(d) our computer systems including IT servers become located overseas or supported by third parties located overseas.
9. Other uses and disclosures
10.1 You consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.
10.2 If you do not want to receive marketing information from us or if you want to stop receiving marketing information, you can unsubscribe in any of the following ways:
(a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us, or
(b) contacting us using the contact details specified in paragraph 15.
11. Storage and security of Personal Information held by us
11.1 We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards.
11.2 If we find that we no longer require or have no further need for your Personal Information we reserve the right to de-identify it or remove it from our systems and destroy all record of it.
12. You can access and update your Personal Information
12.1 You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, we may charge to you the reasonable costs of providing the information, or for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
12.2 A request for access can be made by contacting our Privacy Officer using the contact details specified in paragraph 15.
12.3 We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
12.4 Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.
12.5 It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
13. How do we deal with complaints about privacy?
13.2 It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.
13.3 We will notify you of the outcome of our investigation.
15.1 If you:
(b) wish to make a complaint in relation to a breach of your privacy
(c) would like to access your Personal Information held by us
(d) would like to update or correct your Personal Information held by us, or
(e) would like to opt out of direct marketing,
please contact our Privacy Officer by sending your query or complaint to the following address:
The Privacy Officer
83 Desford Way
Ashford, Middlesex TW15 3AS