Uber9s Limited T/A Uber9s.com Unit 22, Silverstone Technology Park, Silverstone Circuit, Towcester Northamptonshire NN12 8TN
Registered in England 09235903 | VAT Registration Number GB 198 3223 82 | Data protection registration number ZA092610
Telephone: 0333 0066 911
General Data Protection Regulation (GDPR)
The Data Protection Bill, frequently referred to as GDPR (General Data Protection Regulation), replaces the Data Protection Act (1998). There are many similarities between the DPA and GDPR however, there are a few significant differences which bring positive changes to the way personal data is stored and processed. This applies to data held in digital and printed forms where it is used.
The first of the changes under the new regulations, requires businesses to confirm on what basis they believe they should have access to your personal data, either ‘Legitimate Interest’ or full ‘Consent’. At Uber9s we believe that the most transparent and appropriate way for us to serve your needs is with your full ‘Consent’ which must be given freely and without coercion or restriction on our part. At the time you provide your personal data to us we will make it clear to you what you’re providing it for e.g. to complete a specific sale, warranty, refund or newsletter sign-up,
Under this requirement, whatever purpose you initially provide your consent for remains valid for that purpose only. As we continue to serve you, we amalgamate these sources so that we know precisely what we are entitled to use your data for.
GDPR Data Inclusions – Personal Data
Under the regulations the emphasis is that you, our customer and ‘data subject’ are in control of who you provide your personal data to, granting us permission to use it so that we may provide you with the services you choose in support of a commercial relationship with us. Put simply, you are in effect ‘loaning’ us the access rights to your personal data until you see fit to change this arrangement.
Personal data, often referred to as personal information, includes things like your name, address, email address, telephone number(s) and social media accounts, but it can also include things like your account/order number(s), or a unique IP address – anything in fact that can link to you as an individual. This all falls under the protection of GDPR.
GDPR Data Exclusions – Transactional & Location Data
This is different to personal data and includes things related to your purchase history, namely the method you used to make a purchase from us, such as our website and also might also include when you made this purchase. As GDPR’s focus is to protect your personal data, this information is not included under the regulations. However, should you ask to see the data we hold in addition to the personal data we retain, we may still show you examples of this, but this is an extension to our obligations and our way of extending the level of trust and transparency.
GDPR Data Exclusions – Financial Data
This is the third example of data that passes through our business and it includes credit and debit card information. However, the security of this is controlled through other regulations (namely the Payment Card Industry – Data Security Standards) which exists to further reduce your (and our) personal risk. This data bypasses Uber9s’s systems and instead enters a payment gateway to be processed directly between your bank or charge card company, and our financial partner.
Data profiling is a trusted technique that attributes other assumed or known factors to the personal data that you consent to provide us. The process will add things such as: the typical size of your family, the size and approximate value of your home, the occupation you might have, your age range, your propensity to read certain newspapers or respond to email campaigns.
By understanding more about you we believe this will help us to improve the service we offer but we don’t believe we should do this without your consent. So, over the course of your consent we will occasionally seek your approval for this periodically. Under GDPR you will always be able to see what data we hold on you by serving a ‘SAR’ a Subject Access Request upon us (details below).
Processing Personal Data
Under the Data Protection Bill once your data is passed to us, therefore by definition we become the ‘Data Controller’. This definition is the highest definition placed upon us by the ICO and means that we are charged with utmost level of care when it comes to safeguarding your privacy.
Personal, location and transactional data is collected through our businesses systems and is the responsibility of the company’s Data Controller within Uber9s Ltd (within our Privacy Team). You can ask to see or amend what you believe are errors within this data or remove your permission for us to retain it, by reading the steps that we describe next e.g. ‘Subject Access Request’ & ‘Right to be Forgotten’. For anything else, you can always contact our Privacy Team by initially contacting us. Please click here to send an email.
Subject Access Request (SAR)
You can ask to receive a copy of your personal data whenever you choose under a process called a ‘Subject Access Request’. Under a ‘SAR’ we will provide you with a FREE copy of all the personal data we hold on you in a machine-readable format within 30 days of us being able to successfully validate who you say you are. This is particularly relevant in order to avoid any security breaches or false claims for access to your personal data.
If we believe your request is complex or numerous we can extend the process for a further two months, but we will explain to you why this has been necessary within the initial 30 days of us validating who you are. If we deem your requests to be manifestly unfounded, excessive or particularly repetitive we are permitted to charge a reasonable administration fee to comply with requests for further copies of the same information. Should these excessive requests continue we are legally entitled to refuse your request, which should you disagree, you are within your rights to contact the Information Commissioner’s Office and state your claim. All SAR requests are logged within our systems to manage the individual frequency of each request.
Right to be Forgotten (RTBF)
Should you ever decide to refuse us permission to use your personal data, you can invoke your ‘Right to be Forgotten’. In activating this process, we will need to remove all your personal details from our systems. Once removed, this information will not be available to you, or us again, and should you recommence your relationship with us at a future date and provide us with a fresh set of permissions, none of your previous personal data would be available for re-assignment at that stage.
You can invoke your Right to be Forgotten to our Privacy Team by initially contacting us. Please click here to send an email to our data controller.
N.B. Please note that should you decide to invoke your RTBF, we are still required under other company law to store any transactional data that would have once been connected to you as an individual.
A cookie is a piece of computer code – a text file – that is made up of a series of letters and numbers and placed on your device each time you visit our website. Although they may sound sinister to some, they’re actually very useful as they allow us to greatly improve your, and the other users of your devices’, visits to our site, simply by understanding more about your preferences and interests.
Category 1 — Strictly Necessary Cookies
These cookies are essential to enable you to browse around our website and use features. Without these cookies, services like shopping baskets and e-billing cannot be provided.
Category 2 — Performance Cookies
These cookies collect information about how you use our website — for instance, which pages you mostly go to. This data may be used to help optimise our website and make them easier for you to navigate. These cookies are also used to let affiliates know if you came to one of our websites from an affiliate and if your visit resulted in the use or purchase of a product or service from us, including details of the product or service purchased. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.
Category 3 — Functionality Cookies
These cookies allow our website to remember choices you make while browsing. For instance, we may store your geographic location in a cookie to ensure that we show you our website localised for your area. We may also remember preferences such as text size, fonts and other customisable site elements. They may also be used to keep track of what featured products or videos have been viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on other websites.
Links to Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over any other website or your personal data privacy.
Our Responsibility Commitment
The Uber9s Data Controller will be responsible for the storing and processing of your data once you’ve given us your permission to use it. At no stage will your personal data find its way into our systems unless you have willingly and freely provided it to us directly.
In possessing your personal data, we accept that this does not give us the right to abuse its use, and that consequently we will take due consideration of the balance between what we deem to be infringing your privacy and our ability to provide you with timely information, in effect creating a level of ‘Privacy by Design’.
Beyond these options (or the SAR/RTBF methods mentioned above), we will also act in the background in other ways to preserve your personal data privacy. If your entire commercial relationship with us appears to have ceased over a period of five years, then we will automatically obfuscate (that is, to render useless) your personal data.
ICO – Declaration
Should you ever feel that we have not met the regulations our registration details are: Uber9s Limited ICO (Information Commissioner’s Office) registration number ZA092610
… and finally