Privacy Policy
Privacy Policy
- Personal contact details such as your name, title, address, telephone number, e-mail address and your IP address when you visit our website.
- Recruitment information (including personal information such as copies of your right to work documents, your CV or cover letter which is sent to us as part of the application process).
- Information provided to us by recruitment agencies in relation to your application for employment with us.
- Contact details such as your name, title, business telephone number, business e-mail address and your IP address when you visit our website.
- Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
- Bank details of sole traders.
- Personal contact details such as your name, address, telephone number, e-mail address and your IP address when you visit our website.
- Other personal information you provide to us via our website, for example, by using the LiveChat feature via our “contact” page.
- Payment information such as credit/ debit card number, expiration date, security code and name as it appears on the card and the address the card is registered to.
- Personal and payment information that you provide to us at trade shows and expeditions.
- Details which you provide to us in connection with product warranty registration.
- Personal information provided to us via our website or social media accounts, for example, by contacting us on Facebook or Twitter.
- Personal information provided to us during telephone calls which you have made to us and which are recorded.
- Personal information provided to us by the third party service providers we work with, for example, analytics providers and third party companies providing us with marketing assistance.
- Personal details such as your name, address, bank account information, telephone number and your IP address where you visit our website.
- If you enter or apply to enter any of our competitions or events, personal information including your name, e-mail address, telephone number and bank details (if relevant).
- Personal information provided where you enter into one of our competitions via one of our corporate partners.
- If you visit our offices, images and videos are recorded by the CCTV system in operation on our premises.
- Information provided to us over the telephone which is recorded when you call our offices.
- Any personal information provided to us following completion of our ‘Dash Cam Submission Form’.
- Where you feature in content uploaded to our website ‘Operation Snap’.
- Where you feature in content uploaded to our social media pages.
- Where you feature in content provided to us by our dash cam users.
- Any personal data provided to us at any of the trade shows that we take part in.
- Any personal information you provide to us during your interactions with us.
- Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookie Policy.
- Information provided to us by third party service providers we work with, for example, payment service or analytics providers.
- Where you have provided us with your consent for us to do so;
- Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
- Where we need to comply with a legal obligation to which we are subject;
- Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
- To carry out right to work checks – to comply with a legal obligation.
- Your contact details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).
- Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information (where you are an employee of a business) – in pursuit of our legitimate interests in keeping you informed about our products, services and business updates.
- Your bank details (if you are a sole trader) – to perform a contract with you or take steps to enter into a contract with you.
- Dealing with your product related enquiry via remote assistance – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently
- Dealing with your enquiry made via the “Contact” page, the LiveChat feature on our website and / or social media – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
- Your contact details to provide you with marketing information on our products and services – where you have provided us with your consent for us to do so.
- Your personal information that you provide during calls to us – in pursuit of our legitimate interests in order to ensure adequate training and monitoring of our staff.
- Your payment information – to perform the contract with you or to take steps to enter into a contract with you.
- Your personal information for product warranty purposes – to perform the contract with you or to take steps to enter into a contract with you
- Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
- Data collected from the insurance page will be passed to a 3rd party partner organisation (Cornmarket) when requested by the user for the purposes of an insurance quote or call back.
- Your personal details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).
- Your personal details provided to us in connection with the competition that you have applied to enter into – to perform the contract with you or to take steps to enter into a contract with you.
- To ensure our premises are kept secure – in pursuit of our legitimate interests (in ensuring our premises are kept secure and to keep evidence of this).
- Health and safety purposes – to comply with a legal obligation.
- Personal data provided to us at trade shows – in pursuit of our legitimate interests to understand who attended the trade show.
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
- To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
- To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
- To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
- Information provided to us via dash cam footage – in pursuit of our legitimate interests to promote our products.
- Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
- Your personal information provided to us over the telephone – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
- Personal information provided to us via our Operation Snap website – in pursuit of our legitimate interests to assist South Wales Police in keeping the roads safe.
- Technical support providers, for example, assisting with our website.
- Providers assisting us with receipt of payments via our website.
- Recruitment agencies assisting us with filling our vacancies.
- Professional advisers such as lawyers, accountants, insurance companies and business analysts.
- Providers who assist us with shipping, logistics and delivery of our solutions.
- Providers assisting us with the management of our competitions.
- Providers which help us collate and organise information effectively and securely.
- Providers which help us generate and collate surveys and reviews of our products and services.
- Providers which assist us with marketing by, for example, helping us send marketing mailshots.
- Third party software hosting companies which provide us with software solutions.
- Providers which host our servers in their data centres (these are all within Ireland).
- Our competition partners following your entry.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
- Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
- Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months.
- The period we keep your personal information depends on a number of circumstances. For example:
- Where we have collected your personal information during the course of your and our organisations doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
- In the case of sole traders, we will keep your bank account details for as long as we do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
- Where you have provided us with your personal information during the course of making a complaint, we will keep this information for 7 years.
- Where you use our website and one of our cookies are activated, that cookie will operate for the duration set out in our Cookie Policy.
- If you have consented to receiving marketing information, we will keep your personal information for as long as we still have your consent;
- If you have provided us with your personal information for the purpose of making a complaint or a customer service call, we will keep this information for 7 years.
- If you have provided us with your personal information for the purposes of product warranty, we will keep this information for 10 years.
- We will keep your personal information for as long as we and you do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
- We will keep your personal information for a period of 6 years after a competition.
- Any data collected through our CCTV system is stored for 31 days only.
- Images and videos of you which are provided to us and uploaded to any of our websites or applications will be deleted on request.
- Data stored on CamViewer is stored for 30 days only.
- Our server logs which log IP addresses are deleted after 30 days.
- Where you provide us with your personal information at a trade event we will keep your personal information for as long as we have a commercial interest in doing so.
- Where you provide us with your personal information at a trade event for marketing purposes we will keep your information until you withdraw your consent.
- Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal information. This enables you to ask us to delete or remove personal information when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access any personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our premises).
You have the right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
Privacy Notice
This privacy notice explains how we, ExpandNow Limited, (Expand Now) collect, use, and manage your personal data within the Expand Now organisation and for what purposes. Where we refer to “personal data” in this privacy notice, this means data which relates to you as an individual and which personally identifies you either directly or indirectly.
Please read this privacy notice carefully and as this Privacy Notice may change and evolve in the future, we recommend you check back periodically to see if we have made any changes.
Date Processing
There are different definitions of the types of processor of your personal data which are highlighted below for clarification:
- A data processor is an organisation that processes personal data on behalf of another company that is the data controller.
- A data controller is an organisation that collects, uses, and manages personal data and has responsibility for determining how the personal data is collected, used, and managed.
- A data protection officer is the person in an organisation who has responsibility for monitoring compliance with data protection law and for ensuring that personal data is protected within an organisation.
Expand Now uses information gathered from you when you use our website, contact us directly, or sign up to our marketing lists and as such is a Data Controller in these circumstances as it is determining how the data is being processed. Expand Now also acts as the Data Processor in circumstances where it is legitimately processing data on behalf of another business or company to provide goods or services on their behalf.
ExpandNow Limited is registered in Ireland under company number 747757 with its registered office at 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland and its website being www.expandnow.com
We collect personal data when you visit our website and request information by submitting a form on one of our webpages or when you make contact directly via the website, telephone, email, or post directly.
Typically, this information consists of the following, but is not limited to: -
· Name
· Address
· Email Address
· Business Name
· Telephone Number
· Reason for the contact or other relevant information pertaining to the enquiry.
This personal information is used in the following ways: -
· To allow contact following an enquiry for further information or services and to then support the delivery of any subsequent services.
· For marketing purposes to allow us to send you promotions or information on additional services that we may provide. This may also include levels of profiling or to create specific audiences to ensure we market to you about relevant products and services.
· For research and statistical purposes. This includes collecting data about how you use the Site including the content you look at and the monitoring and analysis of your engagement with us. This information is used to identify patterns which we can use in our marketing to help us improve our services and promote Expand Now and to allow Expand Now to develop, manage and administer its relationship with its business contacts and customers.
· To comply with any legal or regulatory obligations which our business is subject to.
By using the Expand Now website www.expandnow.com and accessing any services we offer through the website you are agreeing to be bound by this Privacy Notice in respect of the information collected about you via this Site.
We will also collect personal data when you voluntarily submit information to the Company directly, or via a third party, by way of a job application and/or their submission of a curriculum vitae. Typically, in this instance the mandatory information captured is name, address, email address, telephone number, date of birth with the right to work/visa status also captured further into the recruitment process. All personally identifiable information captured will only be held for as long as it is legitimately required for the purpose of the recruitment assessment, after which point it will then be deleted. The information captured during this process will not be used by the Company for any other purpose, albeit it may be shared with third parties such as recruitment agencies, or HR consultants, who are assisting with the recruitment assessment process.
We may also obtain, collect, and process your Personal Data to provide services directly to yourself as a Data Controller or on behalf of a Third Party, where we are acting as the Data Processor. In this instance we will only capture the information required to process the transaction or provide the goods or services. Typically, the information captured or provided at this point is your full name, contact details, full address, and payment details (if required). We may also verify your age to prevent any unlawful purchases of age restricted products or services.
We need to process your personal data for a number of varied reasons, and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.
We rely on one or more of the following legal bases for processing personal data:
· To perform our contract with you or to enter into a contract with you
We need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is providing goods or services or responding to queries or enquiries.
· To fulfil our legitimate interests or the legitimate interests of a third party
When we process personal data to fulfil our legitimate interests, we will use it in a way in which you would reasonably expect, and which will have a minimal privacy impact. When we or third parties are relying on legitimate interests to process your data, we will balance our interests against your interests and the privacy impact of the processing on you and we will process your personal data responsibly.
Examples of our legitimate interests are direct marketing, fraud prevention, preventing and investigating crime, IT security and development by us and third parties of new products and services.
· To comply with legal obligations to which our business is subject.
We have to comply with relevant law and regulations in order to provide goods and services and we will need to process your personal data in order to comply with these legal obligations.
· Consent
If we are relying on your consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.
Where we are relying on your consent as our legal basis for processing your personal data, you have a right to withdraw this consent at any time. (please see the section below on “Your Rights” for further information)
We take reasonable risk-based measures to protect the data provided via our services which may include pseudonymising or anonymising the personal data. If personal data is pseudonymised, this means it is de-identified so you are no longer identifiable, but we can re-identify you if we have a requirement to do so. If personal data is anonymised, it is de-identified, but can never be re-identified in the future.
However, no internet or email transmission is ever fully secure or error free. Therefore, you should take particular care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the internet.
Like many websites, we use “cookies” to enable us to personalise your visits to this website, keep track of your preferences and to track the usage of this website. Cookies are small pieces of information that are stored on your computer by your browser. Your browser will have the option to prevent websites using cookies (your browser’s help screen or manual will tell you how to do this), but please note that this may reduce the functionality of this Site and other websites.
Like all websites, our servers automatically record ‘log files’ containing information about the volume and characteristics of our website traffic e.g. numbers of pages viewed, length of time spent on site. We use log files to build pictures of how our site is used that help us to monitor and improve the service we provide
The appropriate employees at Expand Now, and where legitimately required relevant partners, supplier and other companies in the Brave Capital Group of Companies have access to the information, including personal information that we have collected from you.
If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners. We will not otherwise disclose, sell, or distribute your information to any third party without your permission unless we are required to do so by law.
How do I change my permissions?
You have certain rights in respect of your personal data, and we have processes to enable you to exercise these rights.
Right of Access
This is known as a Subject Access Request. If you would like to know if we are processing personal data relating to you and you would like to have access to any such personal data, then please email DPO@expandnow.com
Right to Erase
You have a right to ask for your personal data to be erased. However, we are not required to erase your data where we need your personal data to comply with a legal obligation or for the establishment, exercise, or defence of legal claims. If you do wish for your personal data to be deleted, please contact our Data Protection Officer at DPO@expandnow.com. Please note that if you opt out of marketing communications or have previously opted out of marketing communications, we must keep a record, of such opt out to ensure that we do not contact you in the future.
Right to Restriction
You have a right to request that processing of personal data is restricted in certain circumstances. Where we restrict your data, we are permitted to store your data, but we cannot process in any other way apart from for the establishment, exercise, or defence of legal claims or with your consent. If this is required, please contact our Data Protection Officer at DPO@expandnow.com.
If you object to our use of your personal data for direct marketing purposes, or no longer wish to be a part of our community, please email DPO@expandnow.com and let us know. You may ask us to make changes and we will action these as promptly as possible. You can also unsubscribe from receiving emails from us by clicking on the “unsubscribe” link in our emails. Your details will be immediately removed, and we will not contact you again.
You may also object to other processing when we rely on our legitimate interests as the basis for processing, but we do not have to stop the processing if we can demonstrate compelling legitimate grounds for the processing (taking into account our processing activities, the nature of our business and our legitimate interests) and that these grounds override your interests, rights and freedoms or in the event that we need the personal data for the establishment, exercise or defence of legal claims. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to your situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.
Automated Processing/Profiling
From time to time, we may use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.
If you object to our use of your data for targeting through cookies, we will opt you out. You can do this by contacting the Data Protection Officer at DPO@expandnow.com.
Right to Portability
In certain circumstances, you can request that we provide to you your personal data in a commonly used format. If you wish to make such a request, you can contact the Data Protection Officer at DPO@expandnow.com.
Dependent on which country you reside you have the right to lodge a complaint with the Regulator in that Country e.g. for Ireland this is the Data Protection Commission. Prior to lodging a compliant to the Regulator please contact the Data Protection Officer at DPO@expandnow.com or write to us for more information to the Expand Now Data Protection Officer, 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland. All complaints are taken seriously and will be investigated thoroughly and through to resolution.
Changes to our Privacy Notice
Our services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Notice. We reserve the right to update or modify this Privacy Notice at any time and from time to time without prior notice. Please review this notice periodically, and especially before you provide any Personal Data. This Privacy Notice was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.
More Information
If you do have queries about how we use your information or on data protection generally, then please email DPO@expandnow.com or write to us for more information to the Expand Now Data Protection Officer, 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland