Otimo – Privacy & Cookie Policy

Last updated: August 2021

Introduction
Your privacy is important to Otimo. This Policy sets out information on the personal data we collect about you, and your rights in respect of this data. This Policy applies when you download and use our mobile application, Otimo (the “App”). Our App may contain links to third party websites that are not covered by this Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

If you have any comments on this Policy, please email them to gavin@weareotimo.com.

This Policy contains the following information (you can access a specific section of this Policy by clicking below):

  • Information about who we are
  • Information on what we may collect
  • How we store your personal data
  • How we disclose your information
  • When you interact with our App – information on cookies
  • Your rights regarding your personal data
  • What happens when we link to other websites
  • The changes we may make to this Policy

Who We Are
Otimo is operated by Otimo Partnerships Ltd, a limited company registered in England and Wales under company number 11113112. Our registered office is at Hollingwood Business Centre, ℅ Mj Goldman, Albert Street, Oldham, England OL8 3QL.

If you wish to speak to someone about this Policy, please contact us on gavin@weareotimo.com.

We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws.

We comply with the EU law retained version of the General Data Protection Regulation (2016/679), together with the Irish Data Protection Act 2018 and the UK Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with that.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What we may collect
Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you when you engage with us. Whenever we collect personal data about you, we must have a legal ground to do so.

1. Identity and contact information when you download our App and create a profile (as a learner)

Purpose/Activity
Includes your name and email address.

This may also include your postcode, car transmission preference, driving instructor gender preference, provisional licence status and availability.

You may also use the App to track your lessons, including dates and journeys taken.

Lawful Basis
We collect this information when you access the App, in order to set you up with a profile on the App (which allows you to use our services).

Our lawful basis for this is to perform our contract with you – we require this information to be able to provide you with the App. We also ask for your consent when setting up your profile.

We ask for this additional information to provide the services to you, i.e. to obtain enough information to be able to match you with an instructor.

Our lawful basis for this is to perform our contract with you.

This is an optional feature, and allows you to track your experiences during your driving lessons. Our lawful basis for this is to perform our contract with you.

If you choose not to provide the data noted above, we will be unable to provide the App to you (or the full extent of the App to you).

2. Cookies Data

Purpose/Activity
Like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our Website. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.

Lawful Basis
This information is necessary for us to perform our contract with you, i.e., to give you access to the service our Website provides.

We also use this information to study how you use our Website, in order to improve and develop the services we provide, and better inform our marketing strategies.

3. Marketing and Communications Data

Purpose/Activity
Includes your name, email address, residential address and telephone number, as well as preferences in receiving marketing from us and our third parties and your communication preferences.

Lawful Basis
This information is required for us to present relevant content, products and services to you, including our newsletter, subscription updates and blog posts.

We will never contact you for any of the above reasons without you opting in (i.e. providing your consent), and you may unsubscribe from such communications at any time.

When you interact with our App – Information on cookies 
We use cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the UK GDPR. 

Cookies are small text files placed on your device when you visit our App and are used to make the users’ experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of our App; however, for non-essential cookies we need your permission. 

We use cookies to distinguish users and to improve our App. We analyse how you use our App, and we look at aggregate statistics about your usage, and how others use our App. We collect certain information from these cookies, and this includes information about your IP address, your location when you access our App, the date and time you access our App, the language you use and the type of browser you use. 

We do not track individual users or use cookies to identify individuals. We use cookies to recognise you and your preferences, improve our App’s performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do. 

These are the types of cookies we use: 

  • ‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards; and
  • ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our App.
  • Session and Persistent cookies can be either first or third party cookies. A first-party cookie is set by the website or application being visited; a third-party cookie is set by a different website or application. Both types of cookie may be used by us or our business partners.

All of our cookies are categorised by the role they fulfil on our App:

a) Strictly Necessary: these are essential to enable you to move around our App and use features such as secure services. Without these cookies such services could not be provided;

b) Functionality: allow our App to remember your choices and to personalise certain features. These cookies may be anonymised and cannot track your browsing activity on other websites or applications; and

c) Performance: collect information as to how users use our App. These cookies do not collect information that identifies a visitor. The information collected is aggregated and used to improve our App

d) None of the cookies employed are classified as Behavioural Targeting

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you, including some elements of video advertising.

If at any time you wish to disable our cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our App (each time you access our App).

We may process your data for compliance with a regulatory requirement or legal obligation to which we are subject to. Your data will only be processed if processing the data to comply with such obligation is a reasonable and appropriate way of achieving compliance.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

How we store your personal data
We store all of your personal data on our servers within the United Kingdom.

We may transfer your collected data to storage outside the European Economic Area (EEA) or the United Kingdom. It may be processed outside the EEA or the United Kingdom to fulfil your order and to receive access to the App, and deal with payment. If we do store or transfer data outside the EEA or the United Kingdom, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or the United Kingdom. 

This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. 

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our App. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA or the United Kingdom.

We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

How we disclose your information
We may disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer;
  • We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006;
  • We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights; or
  • We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties/subcontractors to supply the App to you on our behalf. These include cloud services used to send emails and technology providers that assist in providing the App to you.

Your rights
When you provide us with personal data, you have certain legal rights, and these include:

  • To request access to, deletion of or correction of, your personal data held by us at no cost to you;
  • To request that your personal data be transferred to another person (data portability);
  • To be informed of what data processing is taking place;
  • To restrict processing;
  • To object to processing of your personal data; and
  • To complain to a supervisory authority.

If you wish to access, rectify, erase or transfer your personal data, please contact us at gavin@weareotimo.com. 

What happens when we link to other websites
This Policy only relates to the App. We might have links on/within the App to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from the App. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

    The changes we may make to this Policy
    We can update this Policy from time to time as laws change or as the App changes. If we make material changes to this Policy, and we need your consent to those changes, we will contact you by email to do so.

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