1. Important information and who we are
By using Coach Hire Exchange (CHX) you will provide certain personal data to us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. By visiting www.coachhireexchange.com you are accepting and consenting to the practices described in this policy.
This website is not intended for use by anyone under the age of 18. We do not knowingly collect data relating to children.
(b) Data Controller
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
(c) Contact Details
Our full details are:
Full name of legal entity: Distinctive Systems Limited
Name or title of DPO: Catherine Whitehead
Email address: GDPR@distinctive-systems.com
Postal address: Amy Johnson Way, York, YO30 4XT
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.
(d) Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 18th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes while you are using the App.
2. The data we collect about you
We may collect and process the following data about you:
- Information you give us. You may give us information about you by: The information you give us may include your name, address, e-mail address and phone number.
- Information we collect about you. With regard to each of your visits to CHX we may automatically collect the following information:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. How we use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following ways:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure of your information
We will share your personal information with other users of CHX when you post a job on CHX or respond to a job request that has been posted. We will use your business’s postal address to locate your business on a map which displays all users of Coach Manager Connect and CHX which is provided to users of our Coach Manager software.
We may also share your data with:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Where we store your personal data
All information you provide to us is stored on our secure servers in the UK. If you are using CHX within the European Economic Area (EEA) your personal data will not be transferred outside of the EEA.
7. Data Security
Where we have given you (or where you have chosen) a password which enables you to access CHX, you are responsible for keeping this password confidential. We ask you not to share your password with anyone outside of your organisation.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to CHX; any transmission is at your own risk. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed once it has been received by us. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any actual or suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
9. Your rights
(a) Data Subject Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data Protection Legislation: (i) until 24th May 2018, the Data Protection Act 1998 then (ii) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (iii) any successor legislation to the GDPR or the Data Protection Act 1998.
GDPR: General Data Protection Regulation ((EU) 2016/679).
Internal Third Parties
Other companies in the Distinctive System’s group acting who are based in the USA and Australia where those companies request support from us on behalf of their customers (i.e. your Employer).
External Third Parties
- Service providers acting as processors based in the UK who provide cloud storage services to us.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Analytics and search engine providers to whom we may share anonymised data to assist us in the improvement and optimisation of our site.