PRIVACY POLICY

This Privacy Policy applies on and from 1 June 2022

1. Introduction

This ‘Privacy Policy’ informs you of the ‘Data’ we are required to collect from you, why we require the ‘Data’, how we handle the ‘Data’ and what your rights are.  It applies to all products and services offered by ‘Happier Campers’ (trading name of VanWurks Ltd).

‘We’ are committed to keeping your personal ‘Data’ safe and secure, and will handle any data received in accordance with our legal obligations.  This ‘Privacy Policy’ describes how ‘Happier Campers’ collect, use, protect and share your personal ‘Data’ when you access or use any website or other digital properties edited by ‘Us’ or/and which this ‘Privacy Policy’ is posted or referenced or when you otherwise interact with ‘Us’, including when you attend where ‘Happier Campers’ are present and when you contact ‘Us’ at the shop.

This ‘Privacy Policy’ is part of the ‘Terms and Conditions’ of ‘Happier Campers’.

We may change this ‘Privacy Policy’ at any time.  If any changes are made to this ‘Privacy Policy’, ‘We’ will notify you by revising the date at the top of the policy or/and include an additional notice on ‘Our’ website homepage.  You should regularly check ‘Our Privacy Policy’ to ensure you have viewed the most up-to-date version.

2. Who’s in control?

‘Happier Campers’ are the “controller” of all personal ‘Data’ collected and used for the purposes set out in this ‘Privacy Policy’.  This means ‘We’ are responsible for deciding how and why any ‘Data’ collected is used and for ensuring this ‘Data’ is handled legally and safely.

3. What ‘Data’ do ‘We’ collect and where from?

‘We’ collect ‘Data’ required in connection of the products and services ‘We’ offer.

The ‘Data’ ‘We’ collect includes:

  • Personal and contact details, such as title, full name and address and contact phone number;
  • Your date of birth and gender (required for rental purposes);
  • Your photo card driver licence and that of any additional drivers (required for rental services);
  • Two forms of proof of address (required for rental services);
  • DVLA checking code to verify alleged driving offences (required for rental services);
  • Information about your health (required for rental services);
  • Information on your profession (required for rental services);
  • Party members (required for rental services);
  • Telematics and driving information about your hired vehicle (including assessing and predicting faults or issues), driving style (including recommending improvements and assessing risk associated with your driving style), location and routes taken.
  • Records of your method contact with us.

Your ‘Data’ is collected when you submit an enquiry, register an account, when you place an order, make a booking for van hire  or when you otherwise contact us either by telephone, email or face to face.

This ‘Data’ is either gathered directly from you via the enquiry/booking form or telephone or face to face (either at the workshop or an event) or from automated methods.

‘We’ may combine ‘Data’ you provide ‘Us’ with ‘Data’ that is collected through automated methods.

‘We’ collect information automatically through the use of cookies and similar technology.  The purposes of collecting this information is described in this ‘Privacy Policy’.  This information includes your IP addresses, device identifiers and information about how long you have stayed on certain pages or what pages you have clicked on (Behavioural Data).

You have the ability to decline cookies when you land on our website.  You can also destroy cookies if you wish, since they are stored on your hard drive.

‘We’ use Google Analytics to collect information above how ‘Our’ website is performing.  ‘We’ do not combine this information with personal identifiable information.  Google Analytics place a permanent cookie on your web browser to identify you as a unique user the next time you visit ‘Our’ website.  This cookie can only be used by Google.  Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the ‘Google Analytics Terms of Use’ and the ‘Google Privacy Policy’. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. For more information on Google Analytics, please visit Google Analytics.

4. What do ‘We’ use your ‘Data’ for?

The General Data Protection Regulation states that ‘We’ have to tell you the legal basis that ‘We’ rely on to process your personal ‘Data’ for the purposes that ‘We’ have notified to you.  ‘We’ use your ‘Data’ (including any data listed in section 3 above) for the following reasons:

  • To respond to an enquiry form received directly from you;
  • To process a booking form a product or service we offer.  This includes considering whether or not ‘We’ are able to offer you the product or service based on the ‘Data’ provided;
  • Updating your records;
  • To manage and administer your order and deliver the products and services in a timely manner;
  • To develop new products and services and to review and improve current products and services;
  • To provide excellent customer service;
  • To provide, maintain and improve on the information, products and services we provide;
  • To monitor and analyse website usage and product trends;
  • To comply with legal and regulatory obligations, requirements and guidance;
  • To share information, as required, with business partners (such as ‘Our’ insurers or designated recovery company).

5. How do ‘We’ process your ‘Data’?

Under the General Data Protection Regulations, ‘We’ must have a valid lawful bases in order to process personal ‘Data’.  There are six lawful bases for processing ‘Data’.  Not all lawful bases apply, but the ones that do apply are as follows:

  1. Consent – In browsing ‘Our’ website or contact ‘Us’ to provide information on ‘Our’ products or services, you are providing your consent to ‘Us’ to process information that may included personal ‘Data’. Where possible, we do try to request your consent such as you agreeing to the use of cookies.  However, there are occasions when you indirectly give your consent, for example, when you send an email to which you would expect a reply.  Unless you have specifically consented to the use of your information for a specific purpose, we do not use your information in any way that would identify you personally.
  2. Contract – A contact is formed between yourself and ‘Us’ when you purchase a product or service from ‘Us’, create an account on ‘Our’ website and/or agree to ‘Our Terms and Conditions’. In order for ‘Us’ to carry out ‘Our’ obligations under that contact, ‘We’ are required to process the information you have provided, some of which will be personal ‘Data’.  This ‘Data’ is processed on the basis that there is a contract between you and ‘Us’.
  3. Legal obligation – On occasion we may have to process your personal ‘Data’ in order to comply with a statutory obligation such as in response to a request for information if ‘We’ are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities.
  4. Legitimate interests – Before processing any ‘Data’ on this basis, ‘We’ will ensure that it was not possible to obtain the information by other means; ‘We’ will ensure that not harm is caused as a result of processing this ‘Data’; and whether you would expect ‘Us’ to process your ‘Data’. Reasons why your personal ‘Data’ may be processed on this basis may be to protect the interests of either you or ‘Us’.

If processing your ‘Data’ is no longer relevant ‘We’ shall immediately stop processing your ‘Data’. If the basis changes, then if required by law, ‘We’ shall notify you of the change and of any new basis under which we have determined that we can continue to process your ‘Data’.

6. Who do ‘We’ share your ‘Data’ with?

‘We’ do need to share your personal ‘Data’ with some third parties. The reason for sharing this information is for:

  • Insurance purposes (for rental services);
  • DVLA checks (for rental services);
  • Guarantee and warranty purposes (on products);
  • In response to a request for information if we are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities.
  • Other organisations and businesses who provide services to ‘Us’ such as accountants, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions.

7. What are your rights

You have a number of rights under Data Protection Law.  ‘We’ will ask for proof of identity and may require more information before responding to the request.

Your rights in in relation to the collection and processing of personal ‘Data’ are as follows:

  1. The right to be informed;
  2. The right to access;
  3. The right to rectification;
  4. The right to erasure;
  5. The right to restrict processing;
  6. The right to data portability;
  7. The right to object;
  8. Rights in relation to automated decision making and profiling.

‘We’ will respond to any ‘requests to exercise your rights’ as soon as we can within 28 days from receiving the request and necessary proof of identification or further information.  If the request is to late longer than 28 days for any reason, you will be notified in writing of the likely response time.

You can request a copy of the personal ‘Data’ that we hold about you.  The request must be made in writing and proof of identity must be provided.

You have a right to ask ‘Us’ to delete your personal ‘Data’.  The request must be made in writing and proof of identity must be provided.

8. Contact Us

If you have any questions about this ‘Privacy Policy’, please contact us by completing our Contact Us Form or by writing to ‘Us’ as:

Happier Campers (trading name of VanWurks Ltd)
Unit E
102 Shaw Road
Oldham
OL1 4AB
United Kingdom