We are Trigen Limited, trading as RoadHow. We are committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data we collect will be processed by us. Please read this privacy notice carefully to understand our views and practices and your rights regarding your personal data. By visiting www.roadhow.co.uk the RoadHow App, or RoadHow Rewards (“our site”), by using our services, or by otherwise providing us with your personal information, it will be processed as described in this notice.
Personal data, or personal information, means any information about an individual from which that person can be identified.
We will collect and process the following data about you:
Information you give us through using our site. This is information about you that you give us by filling in forms on our site (for example, during the RoadHow App registration process or the RoadHow Premium sign-up process) or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number, financial information (such as payment card details), age, vehicle data, previous road traffic convictions (including speeding offences), a scanned copy of your driving licence, and information relating to your driving ability.
This also includes any personal data which you choose to post via our social network or forum and this personal data will be visible to other users of the RoadHow App, so please be careful before you decide to post any of your or a third-party’s personal data and do not ever post any sensitive or potentially harmful personal data.
Information we automatically collect from your use of our site. With regard to each of your visits to our site we will automatically collect the following information:
technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, the whereabouts from which you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service;
location data through your use of the RoadHow App (this can be turned off at any time in the RoadHow App).
Information we develop through your use of the RoadHow Courses. This is information such as facial images and video captured by our facial recognition software, which operates via your webcam or phone camera, when you undertake our online training courses (RoadHow Course/s), and data taken from RoadHow Course results relating to where you excel or need improvement in terms of driving ability (Driver Profile). Your Driver Profile is a form of profiling and will be calculated using an algorithm and will be based on your previous RoadHow Course results. If you are a RoadHow Premium user, you will be able to see your Driver Profile. If you disagree with any aspect of your Driver Profile, please let us know using the details provided under the ‘Contact Us’ section. Your Driver Profile will be made up of the following real-time cumulative condensed scores:
RoadRating - representing your collated scores across all RoadHow Courses taken.
Willingness to Learn - representing your willingness to learn from any mistakes you have made and how often you are prepared to spend time improving your knowledge.
Strengths and Weaknesses - individual scores representing your collated strengths and weaknesses for each RoadHow Course taken.
Manipulation Index - representing your attempts – if any – to try to manipulate the RoadHow Courses, RoadHow App, or our site to dishonestly improve your Driver Profile (this measure is to identify attempted fraud and cheating).
Please note that RoadHow will never make fully automated decisions based on your Driver Profile. However, if you are a RoadHow Premium user there will be circumstances where this data is shared with your car insurance provider (Insurer) or another third-party insurer (please see ‘Why do we collect this information’ for details on when this might happen), your Insurer or another third-party insurer may use it to make automated decisions that affect you (for example, when deciding whether to offer you a contract of insurance or a particular incentive). Please refer to your Insurer’s, or relevant third-party insurer’s, privacy notice for further information on this.
Information we collect when you call us. If you call us, we will automatically collect the phone number used to call us.
Information we receive from other sources. Unless other RoadHow App users create posts that contain your personal data (for example, your name), we do not receive any personal information from third-party sources, but if this changes we shall notify you by updating this privacy notice.
We process your personal information for the following reasons:
Pursuant to a contract in order to:
process information at your request to take steps to enter into a contract;
provide you with our services, which include providing the RoadHow Courses, developing your Driver Profile and, in the case of RoadHow Premium users only, sharing information (such as your RoadHow Course results and your Driver Profile) with your Insurer pursuant to a contract of insurance that you have with RoadHow or your Insurer, or are being offered by your Insurer. For example, your contract of insurance may require you to undertake RoadHow Courses to enable your Insurer to evaluate your driving performance and offer you incentives accordingly;
maintain business and service continuity;
send service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email or push notifications via the RoadHow App. These will include notifications about changes to our service and reminders to complete RoadHow Courses in order to maximise incentives offered by your Insurer. These service communications will not constitute marketing and we will not ask for your consent for these communications.
Failure to provide certain personal data to us may result in us not being able to carry out the actions referred to above or your Insurer not being able to offer you certain contractual benefits related to RoadHow.
On the basis of your consent:
where we rely on your consent for processing, this will always be brought to your attention when the information is collected from you and you will have the option to withhold your consent;
you have the right to withdraw consent at any time. See the ‘What are your rights?’ section below for more information.
From time to time RoadHow will market its services, and the services of carefully chosen RoadHow Partners, to you on the basis of your consent as follows:
we will contact you with direct electronic marketing communications (for example, emails or RoadHow App push notifications) that advertise RoadHow’s services and other similar services unless you choose to opt out (which you can do at any time via the RoadHow App or our site);
we will only contact you with direct electronic marketing communications that advertise the goods and services of our carefully chosen RoadHow Partners if you have explicitly consented to receive those communications from those specific third parties. These communications will always be relevant to RoadHow and your driving experience and they will always be sent by us - the RoadHow Partners will not have access to your personal data for these purposes.
Please note that the our site may also advertise the goods and services of our carefully chosen RoadHow Partners via ‘in-site marketing’ (for example, in-app banners). This marketing will not be targeted to you and will not be based on your consent.
In our legitimate interests of providing the best service and improving and growing our business, we will process information in order to:
provide the RoadHow App social network and forum;
provide you with a personalised service;
improve our products and services;
keep the RoadHow App, our site and systems safe and secure;
protect against fraudulent use of your subscription account;
understand our customer base and purchasing trends;
defend against or exercise legal claims and investigate complaints; and
understand the effectiveness of our marketing.
We will carry out analytics to improve our services as set out above.
If you are a RoadHow Premium user, we may also share your Driver Profile with third-party car insurers to enable them to better forecast their future liability and to price their insurance products to you more accurately and competitively. For RoadHow Premium users, it means that insurance policies are priced more fairly, with the lowest-risk individuals paying less for their insurance. This sharing will only take place if a third-party insurer is preparing a quotation at your request.
You have the right to object to processing carried out for our legitimate interests. See the ‘What are your rights?’ section below for more information.
To comply with legal requirements relating to:
the provision of services;
health and safety;
assisting law enforcement; and
any other legal obligations placed on us from time to time.
We will keep information about you for a maximum of 6 years after the end of our relationship with you unless obligations to our regulators require otherwise or we are required to remove such data from our records.
At RoadHow, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service (for example, a password to access your subscription account), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
If we transfer your data outside the UK (or, if you are based in the EU, the EEA), we will only do so if adequate protection measures are in place in compliance with data protection legislation.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. More information is available by contacting us.
Where processing of your personal data is based on consent, you can withdraw that consent at any time. You can do this by following links in our emails or by changing your settings in the easy-to-use RoadHow App.
You have the following rights. You can exercise these rights at any time by contacting us at email@example.com or RoadHow, PO Box 17700, SOLIHULL, B93 3JA. You have the right:
to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
to ask us not to process your personal data where it is processed on the basis of legitimate interests, provided that there are no compelling reasons for that processing;
to ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest;
to request from us access to personal information held about you;
to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
to ask for data to be erased, provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate grounds for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/.
This notice may be updated from time to time. Please check back frequently to see any updates or changes to our privacy notice.
For the purpose of data protection legislation, the data controller is Trigen Limited. Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Trigen Limited at firstname.lastname@example.org or at RoadHow, PO Box 17700, SOLIHULL, B93 3JA.