Privacy Policy

Bluesona LTD are committed to respecting and protecting your privacy

This privacy policy tells you what to expect when Bluesona collects and processes your personal data.

Bluesona collects and uses information about people with whom it communicates. This personal information must be dealt with properly and securely however it is collected, recorded and used– whether on paper, in a computer, or recorded on other material. There are safeguards to ensure this in the Data Protection Act 1998 .

Bluesona regards the lawful and correct treatment of personal information as very important tot he successful and efficient performance of its functions, and to maintain confidence between those with whom it deals. To this end Bluesona fully endorses and adheres to the Principles ofData Protection, as set out in the Data Protection Act 1998. (DPA)

Generally, we do not have a direct contractual relationship with individual drivers; normally we have a contract with a 3rd party which is typically your employer, your insurer or the owner of your vehicle (the Contracting Entity).

It is very important that you read this Privacy Notice in full so that you understand what information we collect from you and from the Loop and how we then process this information.

This Privacy Notice only covers the processing performed by Bluesona and its sub-processors; it does not cover the processing performed by the Contracting Entity.

It is therefore important that you also read the Privacy Notice provided by the ContractingEntity to obtain a full picture of the processing being undertaken.

Phrases which start with capital letters (such as “Privacy Notice”) are defined in the Definitions section at the end of this notice.

Note that, Drivers must make a copy of this policy available to a Nominated Driver or AssociatedPerson on request.

Where you have any concerns about the information collected or how your information may be used, you should discuss in the first instance with the relevant individual within your organisation.

Revisions to this Privacy Policy

As the needs of the business develop, there may need to be revisions to this Privacy Policy. You should refer back to our website from time to time to view the latest Privacy Policy.

Controller / Processor status

In order to meet the requirements of the principles of the DPA, Bluesona adheres to the following values when processing personal data:

Fair Collection and Processing

Under Data Protection legislation, Bluesona Ltd operates as both a Data Processor and a Data Controller
of your personal information in conjunction with the Contracting Entity (normally your employer, the
vehicle owner or your insurer).

The Contracting Entity are responsible for defining the Purpose for processing your personal information
and for ensuring a Lawful Basis for that processing. Bluesona are responsible for determining what
information to collect from the Loop software in order to fulfil the stated purpose.
Typically, retention periods for data are defined by the Contracting Entity as part of the contractual
agreement, to reflect the Contracting Entity’s legal and organisational requirements.
Enquiries relating to the Retention of data should be directed to the relevant person at the Contracting
Entity in the first instance.
Bluesona may retain data for a longer period where we deem it necessary to reflect our own legal and
organisational requirements.

Lawful Basis

Bluesona and our partners will collect, process and will pass this information to the Contracting Entity
under our Legitimate Interests in order to provide the Service.
The Contracting Entity will have their own, separate Lawful Basis for their initial collection and processing
of personal data and the subsequent processing of the information provided by Bluesona.
Enquiries relating to the Contracting Entity’s Lawful Purpose should be directed at the relevant individual
within your organisation

What data do we collect when you register for our Services?

When registering for our Service, we will typically collect such information as may be required to set up
and deliver the Service. This information may include such items as:
• Name
• Home Address
• Home Phone Number
• Mobile Phone Number
• Date of Birth
Note that this information may be collected directly from the Data Subjects or may be provided to
Bluesona LTD by the Contracting Entity.

What data do we collect from your mobile device?

When using the Loop App, we will process your device Location and Speed. We transmit live data from your Mobile device to Bluesonas hosting platform in the event of an Infringment.


Use of Mobile Device Data

When using the Loop, Bluesona are not responsible for and additional charges which may be incurred as a result of mobile data charges from your carrier.

Third Parties

We use your information only as set out in this Policy and will not sell, rent or pass your information on to others for marketing or other purposes without your express consent.

Bluesona may however provide aggregate statistics about our customers, sales traffic patterns and related site information to reputable third-party vendors and relevant affiliate partners, but these statistics will include no personally identifying information.

We may also release account and driving data where we believe in good faith that this release is reasonably necessary to comply with the law.


Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.


Your Rights - Controlling your personal information

Under data protection legislation, you have the right to:

• Request access to the personal data we hold about you and details of any other party we share that data with;
• Request a copy of the personal data that we hold about you;
• Request that we correct your personal data when it is incorrect, out of date or incomplete;
• Request that we stop using your personal data for direct marketing communications;
• Request that we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that Bluesona holds at any time, and also to have that information corrected if it is inaccurate.


Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. We will then cease processing your data for that purpose.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

If we decide not to action your request we will explain to you the reasons for our refusal.

You may also request that some or all of your data is deleted; however, the Right to Erasure is not absolute and we may decide to retain the data if we have an overriding reason for doing so.

If we decide not to action your request we will explain to you the reasons for our refusal.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.


Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.


Making and Dealing with Requests

Any requests relating to this Service and the Personal data being processed will be handled jointly between Bluesona and the Contracting Entity.


Requests relating to your personal data should be made to the Contracting Entity in the first instance – details of how to do that will be included in the relevant Privacy Notice provided by the Contracting Entity.

However, if you so wish, you are also able to make such as request directly to Bluesona via email at info@bluesona.co.uk or by writing to:


Data Protection Officer

Bluesona

Innovation House
Belfast Rd

Downpatrick

BT30 9UP

UK

Contacting the Regulator

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.


The Information Commissioner’s Office can be contacted via telephone on 0303 123 1113 or online at www.ico.org.uk/concerns

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.


Additional Questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:


Email us at: info@bluesona.co.uk or write to us at:

Data Protection Officer

Bluesona

Innovation House
Belfast Rd

Downpatrick

BT30 9UP

UK



Definitions


App – software application typically installed on a mobile device.

Contracting Entity – the entity entering into the contract with Bluesona and on whose instructions the Service is provided. This is typically your employer, your insurer or the vehicle.

Customer Personal Data - personal data contained in the Data or otherwise collected from the Customer, and which is processed by the Supplier in the course of performing its obligations and for the other purposes set out herein.


Data - Telematics Data, Driver Profile Data, Diagnostic Data, FNOL, Battery Status Data;

Data Protection Legislation - 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 any successor legislation to the foregoing;

Mobile Device – smartphone or similar

Personal data, process, data controller, data processor and data subject - have the meanings given in the Data Protection Legislation

Service – the full range distraction driving and UBI services provided by Bluesona LTD and its subsidiary companies.

Version 1.0 Updated 11/06/19



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