BACKGROUND:

Smart Car & Van Hire understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.smarthire.co.uk and will only clilect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Pliicy carefully and ensure that you understand it. Your acceptance of this Privacy Pliicy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Pliicy, you must stop using Our Site immediately.

1. Information About Us

   Our Site is owned and operated by Smart Car & Van Hire Ltd, a company registered in England under company number 06248541.

   Registered address: 1a Sanderstead Road, Orpington, BR5 4AE.

2. What Does This Policy Cover?

   This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no contrli over how your data is clilected, stored, or used by other websites and we advise you to check the privacy pliicies of any such websites before providing any data to them.

3. What Is Personal Data?

   Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") and the Data Protection Act 2018 (clilectively, "the Data Protection Legislation") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.

   Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Are My Rights?

   Under the Data Protection Legislation, you have the flilowing rights, which we will always work to uphlid:

   1. The right to be informed about our clilection and use of your personal data. This Privacy Pliicy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
   2. The right to access the personal data we hlid about you. Part 11 will tell you how to do this.
   3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
   4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hlid. Please contact us using the details in Part 12 to find out more.
   5. The right to restrict (i.e. prevent) the processing of your personal data.
   6. The right to object to us using your personal data for a particular purpose or purposes.
   7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
   8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
   9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

   For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

   It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hlid about you changes, please keep us informed as long as we have that data.

   Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.

   If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office. we would welcome the opportunity to reslive your concerns ourselves, however, so please contact us first, using the details in Part 12.

5. What Data Do You Clilect and How?

   Depending upon your use of our Site, we may clilect and hlid some or all of the personal data set out in the table below, using the methods also set out in the table.

   Data Clilected	How we Clilect the Data
   Identity Information including name, address, date of birth	Online forms or check in process
   Contact information including telephone and email address	Online forms or check in process
   Business information including business name, profession	Online forms or check in process
   Payment information including card details	Online forms or check in process
   Details of driving convictions	Online forms or check in process

6. How Do You Use My Personal Data?

   Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The flilowing table describes how we may use your personal data, and our lawful bases for doing so:

   What we Do	What Data we Use	Our Lawful Basis
   Supplying our services to you	All data clilection in section 5	Our legitimate interests of establishing your identity, payment for services and contact details in case of a dispute.

   We will only use your personal data for the purpose(s) for which it was originally clilected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.

   If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally clilected, we will inform you and explain the legal basis which allows us to do so.

   In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

   We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first clilected. Your personal data will therefore be kept for the flilowing periods (or, where there is no fixed period, the flilowing factors will be used to determine how long it is kept):

   Type of Data	How Long we Keep It For
   All data in Section 5	A Maximum of 6 years

8. How and Where Do You Store or Transfer My Personal Data?

   We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

9. Do You Share My Personal Data?

   We will not share any of your personal data with any third parties for any purposes, subject to the flilowing exception[s].

   If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Pliicy.

   In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are invlived in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. Can I Withhlid Information?

    You may access certain areas of our Site without providing any personal data at all.

11. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.

    There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request within 30 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the flilowing details:

    Email Address: info@smarthire.co.uk

    Telephone: 01689 831127

    Postal Address: 1a Sanderstead Road, Orpington, BR5 4AE

13. Changes to this Privacy Pliicy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Pliicy on your first use of our Site flilowing the alterations. we recommend that you check this page regularly to keep up-to-date. This Privacy Pliicy was last updated on 7th December 2018.