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Privacy Policy

CarVue, CustomerVue and BayConnect are applications created and operated by Autino Ltd, a UK company based in Reading, Berkshire.

At Autino we understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits any of our Sites and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law of the land from which our sites are operated (UK). Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of any of Our Sites. If you do not accept and agree with this Privacy Policy, you must stop using all of our sites immediately.

1. Definitions and Interpretation

In this Privacy Policy, the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of any of Our Sites; “Cookie” means a small text file placed on your computer or device by any of Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 13, below; “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; “Our Sites” means the following websites operated by Autino Ltd from the UK:

www.autino.com Autino corporate website
www.carvue.com CarVue corporate website
www.customervue.com CustomerVue corporate website
www.bayconnect.com BayConnect corporate website
app.carvue.com CarVue application website
app.customervue.com CustomerVue application website
account.bayconnect.com BayConnect application website

personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Sites. This definition shall, where applicable, incorporate the definitions provided in the UK Data Protection Act 1998 and/or EU Regulation 2016/679 – the General Data Protection Regulation (the “GDPR”); “We/Us/Our” means Autino Limited.

2. Information About Us

2.1 Our Sites are owned and operated by Autino Limited a limited company registered in England under company number 09332116, whose registered address is 83 – 85 London Street, Reading, Berkshire, England, RG1 4QA. 2.2 Our VAT number is 201261080. 2.3 Our Data Protection Officer can be contacted by email at infosec@autino.com, by telephone on +44 (0)3333 444 765, or by post at the address above. 2.4 We are regulated by The UK Information Commissioner’s Office (ICO).

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of any of our Sites. Our Sites may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject and with effect from 25 May 2018 you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data; 4.1.2 The right of access to the personal data We hold about you (see section 12); 4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14); 4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14); 4.1.5 The right to restrict (i.e. prevent) the processing of your personal data; 4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation); 4.1.7 The right to object to Us using your personal data for particular purposes; and 4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. 4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Sites, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy www.autino.com/cookie-policy :

5.1 name; 5.2 contact information such as your email address, postal address and telephone number; 5.3 email address; 5.4 IP address; 5.5 web browser type and version; 5.6 operating system; 5.7 a list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to;

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK Data Protection Act 1998 and/or, with effect from 25 May 2018, the EU GDPR at all times. For more details on security see section 7, below. 6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account; 6.2.2 Providing and managing your access to Our Sites; 6.2.3 Personalising and tailoring your experience on Our Site; 6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you); 6.2.5 Personalising and tailoring Our products and services for you; 6.2.6 Replying to emails from you; 6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by unsubscribing from emails; 6.2.8 Market research; 6.2.9 Analysing your use of Our Sites and gathering feedback to enable Us to continually improve Our Sites and your user experience;

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the UK Data Protection Act 1998 and the GDPR (as appropriate) and the Privacy and Electronic Communications (EC Directive) Regulations 2003. 6.4 Third parties whose content appears on Our Sites may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties. 6.5 If you post or send offensive, inappropriate or objectionable content anywhere on or to Our Sites or applications, or otherwise engage in any disruptive behaviour or behaviour which is in breach of any applicable law, We may use your personal information to stop such behaviour. 6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. 6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will be deleted when you cancel the contracted service you have purchased from us, request in writing that your data is deleted and if it is legal for us to delete it.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it. 7.2 Depending on which of Our Sites you are using and where you are geographically located determines where your data is stored:

Site URL Data storage location
Autino corporate website www.autino.com The EEA
CarVue corporate website www.carvue.com The EEA
CustomerVue corporate website www.customervue.com The EEA
BayConnect corporate website www.bayconnect.com PII data in EEA, sign-on data in USA
CarVue application website App.carvue.com 1. The EEA for EU users 2. The USA for USA and South America users 3. APAC for APAC users
CustomerVue application website App.customervue.com The EEA
BayConnect application website Account.bayconnect.com The EEA

The “EEA” means the European Economic Area. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. Steps We take to secure and protect your data include but are not limited to:

7.3.1 Hosting of our systems within highly secure commercial data centres that themselves conform to the highest certified levels of security such as ISO27001. 7.3.2 Designing and building services with the “Privacy by Design” ethos from the start. 7.3.3 Training our staff in how to write secure code. 7.3.4 Adopting a culture of good security. 7.3.5 Monitoring, measuring and alerting of our own services 24x7. 7.3.6 Using external security testing services to “ethically hack” our own systems in order to find issues before anyone else does.

8. Do We Share Your Data?

8.1 We may share your data with other companies in Our group. This includes Our subsidiaries and Our holding company and its subsidiaries. 8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. 8.3 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law. 8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK Data Protection Act 1998 or GDPR. 8.5 For data that is entered in the EEC but transferred out of the EEC to the USA your data is protected as the Third Parties are authorised by the EU to be covered by the EU-USA Privacy Shield. 8.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.]

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us. 9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner.

10. How Can You Control Your Data?

10.1 In addition to your rights under the EU GDPR (if you are an EU citizen) set out in section 4, when you submit personal data via Our Sites, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account(s) on any of Our Sites). 10.2 For UK based users you may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data. 11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy www.autino.com/cookie-policy.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Act 1998, We require the payment of a small fee which will not exceed £30. Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the details in section 2.

13. Our Use of Cookies

Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our products and services. By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Sites for providing analytics services. Analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. For more details, please refer to Our Cookie Policy www.autino.com/cookie-policy.

14. Contacting Us

If you have any questions about Our Sites or this Privacy Policy, please contact Us using the details in para 2.3. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of any of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.

Last updated: 13th April 2018