PRIVACY POLICY

Welcome to SILVA BROTHERS GROUP LIMITED’S (SBL Couriers) privacy policy

This privacy policy sets out how SBL Couriers uses and protects your personal data.

  1. Important information and who we are

Privacy policy

This privacy policy gives you information about how SBL Couriers collects and uses your personal data through your use of this website, including any data you may provide when you register with us or purchase a service from us.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

SBL Couriers is the controller and responsible for your personal data (collectively referred to as “SBL Couriers  “, “we”, “us” or “our” in this privacy policy).

SBL Group (Group) is made up of different legal entities, including but not limited to SILVA BROTHERS LOGISTICS LTD and DAILY VEHICLE RENTAL LIMITED. This privacy policy is issued on behalf of the Group so when we mention “SBL Couriers”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. SILVA BROTHERS LOGISTICS LTD is the controller and responsible for this website whereas DAILY VEHICLE RENTAL LIMITED is the controller and responsible for the renting of vehicles to you.

  1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you interact with and use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • CCTV and other camera footage includes where available, CCTV video recordings and/or photographs of you in public areas of our rental locations.

We may also collect, use, store and transfer the following information, when you rent a vehicle, including being added as an authorised additional driver or when you provide us with an emergency contact:

  • Driving Qualifications and Identify Verification Data includes driving licence information and photos provided by you or images for verification, insurance information, passport, proof of residence.
  • Claims Information Data includes information related to details of accidents involving our vehicles, including that of any third parties such as involved individuals, witnesses and police reports.
  • Health Data includes information about relevant health conditions you have that assist us in providing you with adaptive driving devices, or related to claims involving injuries.
  • Emergency Contact Data includes details of your relationship with your emergency contact as well as their name and contact details.
  • Vehicle Data includes:
    • Fuel information: We use this information to facilitate recording and billing for fuel charges.
    • Odometer information: We use this information to facilitate billing for mileage charges (where applicable) and to help us manage our fleet.
    • Vehicle diagnostic and performance information: We use such information to help us identify vehicle maintenance needs and to manage the fleet.
    • Mobile device or app connections to help us issue certain commands to the vehicle to facilitate or expedite your rental other transaction: For example, we may collect information that enables us to remotely unlock or lock the vehicle doors.
    • Telematics data: We collect and use vehicle location information to:
      • Enable our roadside assistance providers to provide you with roadside assistance.
      • Enable emergency service providers to dispatch emergency services to you.
      • Assist us in recovering a vehicle we reasonably believe is lost, stolen or abandoned.
    • Event data recorders: in certain claims situations we may use this information in connection with accident investigations and claims-related efforts.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Your appointment as an emergency contact. We may receive your personal data if it has been provided to us by a customer who has listed you as an emergency contact.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data is collected from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  • Identity and Contact Data is collected from data brokers or aggregators.
  • Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
  • When you drive our vehicles. Where our vehicles are equipped with telematics devices such as pre-installed event data recorders, global positioning devices, and other communications systems that may be connected to the internet or cellular services, we (and at times the vehicle manufacturer and other authorised third parties), may receive data. This data is associated with the vehicle only and maintained as de-identified or anonymised data and will only be linked for the purposes and in the situations described below. Any information that is linked to you will be treated as personal information in accordance with this Privacy Policy.  You are responsible for informing passengers and other drivers that vehicle data is collected and used as described in this section.

The use of telematics devices and other pre-installed services and technologies are subject to our rental terms and conditions and, in some cases, the vehicle manufacturer’s and/or technology provider’s terms and conditions and privacy policy.  Some or all of these features may be turned on at all times, even when other services or other media in the vehicle are turned off.  If you are unsure whether your rental vehicle contains telematics devices or technologies or systems, please speak to a member of our team at the rental location.

We may share vehicle information, including location information, where legally compelled or in emergency circumstances. 

We retain vehicle information based on retention periods in accordance with our business needs and legal requirements.  We may use and store this data after the expiry of our contract with you.

  • Infotainment systems and vehicle manufacturer apps.

If you pair a mobile device with our vehicles’ navigation or infotainment systems and choose to use OnStar, Apple CarPlay, Android Auto or other similar third-party software, application, virtual assistant, video or voice recording devices, features, setting, profiles or services on the vehicle or if you choose to use any navigational features on the vehicle’s infotainment systems or other device, your personal information and other data may be transferred and stored on these systems. We cannot guarantee the privacy or confidentiality of such information. You should delete all such personal information and other data from these systems or devices before the vehicle is returned to avoid subsequent occupants of the vehicle accessing this information.

  1. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  • Vital interests: We may use your personal data when it is necessary to protect a vital interest, either for your own life (if you are a customer) or for the life of another person (if you are listed as an emergency contact for one of our customers).

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

Type of data

Legal basis

To register you as a new customer

a)    Identity

b)    Contact

c)     Driving Qualifications and Identify Verification

a)    Performance of a contract with you

To process and deliver your order including:

·         Manage payments, fees and charges

·         Collect and recover money owed to us

·         Provide vehicle rental services

·         Extend insurance coverage to you if applicable

a)    Identity

b)    Contact

c)     Financial

d)    Transaction

e)    Purchase

f)      Driving Qualifications and Identify Verification

g)    Vehicle

h)    Emergency Contact

a)    Performance of a contract with you

b)    Necessary for our legitimate interests (to recover debts due to us)

To collect data relating to the vehicle’s condition and performance during the rental (including vehicle damage, mileage, fuel use and other operational data) to improve the accuracy of our billing processes on return of the vehicle

a)    Transaction

b)    Profile

c)     Vehicle

a)    Necessary for our legitimate interests (to ensure accurate charging for your uses of the vehicle, including for fuel and damage where applicable)

To manage our relationship with you which will include:

·        Notifying you about changes to our terms or privacy policy

·        Dealing with your requests, complaints and queries regarding our website or a vehicle you have rented from us

a)    Identity

b)    Contact

c)     Transaction

d)    Profile

e)    Marketing and Communications

f)      Usage

g)    Vehicle

a)    Performance of a contract with you

b)    Necessary to comply with a legal obligation

c)     Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

a)    Identity

b)    Contact

c)     Technical

d)    Profile

e)    Usage

a)    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

b)    Necessary to comply with a legal obligation

To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

a)    Identity

b)    Contact

c)     Technical

d)    Profile

e)    Usage

f)      Marketing and Communications

a)    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

a)    Technical

b)    Usage

c)     Vehicle

a)    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

a)    Identity

b)    Contact

c)     Technical

d)    Profile

e)    Usage

f)      Marketing and Communications

a)    Consent, having obtained your prior consent to receiving direct marketing communications

To carry out market research through your voluntary participation in surveys

a)    Identity

b)    Contact

c)     Marketing and Communications

a)    Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

To facilitate your safety in enabling roadside assistance providers to provide you with roadside assistance and enable emergency service providers to dispatch emergency services to you.

a)    Identity

b)    Contact

c)     Driving Qualifications and Identify Verification

d)    Health

e)    Vehicle

f)      Emergency Contact

(a)       Consent, having obtained your prior consent to any services being provided

(b)       Vital interests, if consent is not able to be obtained (e.g., in a medical emergency).

To assist us in recovering a vehicle we reasonably believe is lost, stolen or abandoned. 

a)    Identity

b)    Contact

c)     CCTV

d)    Driving Qualifications and Identify Verification

e)    Claims Information

f)      Vehicle

g)    Emergency Contact

a)    Necessary to comply with a legal obligation

b)    Necessary for our legitimate interests (to protect our assets, enforce our terms and conditions, manage and defend any claims, and recover any debts)

To collect data relating to the driver’s operation of the vehicle during the rental for safety, security and claims management reasons.

a)    Identity

b)    Contact

c)     CCTV

d)    Driving Qualifications and Identify Verification

e)    Claims Information

f)      Health

g)    Vehicle

a)    Necessary to comply with a legal obligation

b)    Necessary for our legitimate interests (to ensure compliance with our insurance requirements, to recover any debts, and defend and manage any claims relating to damages or injuries)

To assist us in providing you with adaptive driving devices

  

To maintain security at our places of business and rental locations.

a)    Identity

b)    CCTV

(a)      Necessary for our legitimate interests (maintaining security and prevention of crime at our places of business and rental locations)

To comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process

a)    Identity

b)    Contact

c)     Financial

d)    Transaction

e)    Technical

f)      Profile

g)    Usage

h)    Marketing and Communications

i)      CCTV

j)      Claims Information

k)     Health

l)      Emergency Contact

m)   Vehicle

a)    Necessary to comply with a legal obligation

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us info@daily-rental.co.uk.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see [LINK TO YOUR COOKIE POLICY.

  1. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • Any of our affiliates which include any entities that we directly or indirectly control, are controlled by, or are under common control with us from time to time.

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.

  1. International transfers

We do not usually transfer your personal data outside the UK.

  1. Data security

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. 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 suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us – see Contact details (paragraph 10).

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 could 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 could 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.

  1. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: dpo@daily-rental.co.uk

  1. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

  1. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

  1. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.