Privacy Policy for Express Recovery

Last updated: 1st June 2025

Express Recovery ("we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, process, and protect your personal information in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other relevant UK legislation. We aim to be transparent about our data practices and ensure you understand your rights regarding your personal data.

1. Who We Are (Data Controller)

Express Recovery acts as the Data Controller for the personal data we process. This means we determine the purposes and means of processing your personal data. Our contact details are provided at the end of this policy.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, title, date of birth, and gender.
• Contact Data: Includes email address and telephone numbers.
• Vehicle Data: Includes vehicle make, model, registration number, and any specific vehicle issues or recovery requirements.
• Technical Data: Includes internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Includes information about how you use our website, such as pages viewed, time spent on pages, and navigation paths. This data is collected to understand website performance and user behaviour for analytical purposes.
• Marketing and Communications Data: Includes your preferences in receiving marketing communications from us, and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Please note: Our website does not facilitate online transactions or store financial or billing/delivery address data. Information submitted through our contact form (such as Identity, Contact, and Vehicle Data) is sent directly to us via email for the purpose of responding to your enquiries or facilitating a booking, and is not stored directly on the website's servers.

3. How Your Personal Data is Collected

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

• Direct interactions: You may give us your Identity, Contact, and Vehicle Data by filling in our contact form or by corresponding with us by post, phone, or email. This information is sent directly to us to enable us to respond to your enquiry or process a booking. This includes personal data you provide when you:
  • Enquire about or request our services;
  • Request marketing communications from us; or
  • Give us feedback or contact us.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. This is primarily for analytical purposes to understand website traffic, popular keywords, and to improve site visibility and customer acquisition. Please see our Cookie Policy for further details.
• Third parties or publicly available sources: We may receive Technical Data from analytics providers such as Google to help us understand website performance and user behaviour. We may also receive Identity and Contact Data from publicly available sources if you have made your information public and it is relevant to our services.

4. How and Why We Use Your Personal Data (Lawful Basis)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (e.g., to provide vehicle recovery services after you contact us).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., for website analytics to improve our services and marketing).
• Where we need to comply with a legal or regulatory obligation.
• Where you have given us consent to do so (e.g., for certain marketing communications or non-essential cookies).

Below is a table outlining the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes stated in section 4:

• Internal Third Parties: Other companies within our group acting as processors or joint controllers and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
• External Third Parties:
  • Service providers acting as processors who provide IT and system administration services (e.g., email service providers for contact form submissions).
  • Professional advisers acting as processors or joint controllers including lawyers, auditors, and insurers who provide consultancy, legal, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Analytics and search engine providers (e.g., Google Analytics) that assist us in the improvement and optimisation of our site, understanding user behaviour, and marketing effectiveness.
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

6. International Transfers

We do not routinely transfer your personal data outside the UK or the European Economic Area (EEA). However, should it become necessary to transfer your personal data outside these regions, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Information Commissioner's Office (ICO).
• Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

7. 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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances, we may 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.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:

• The right to be informed: You have the right to be informed about the collection and use of your personal data. This Privacy Policy serves to fulfil this right.
• The right of access: You have the right to request a copy of the personal data we hold about you. This is commonly known as a ‘data subject access request’.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure (also known as 'the right to be forgotten'): You have the right to request that we erase your personal data, under certain conditions. This is not an absolute right and only applies in certain circumstances.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions, particularly where we are relying on a legitimate interest.
• The right to data portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
• Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• The right to withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details provided in section 11. 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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. Complaints

We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal data, please contact us in the first instance at expressrecovery57@gmail.com. We will respond to your complaint as soon as we can.

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

11. Changes to This Privacy Policy

We keep our Privacy Policy under regular review and may update it from time to time. Any changes will be posted on this page, and the "Last updated" date at the top of this policy will be revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

12. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

• By email: expressrecovery57@gmail.com
• By phone: 07308776755
• By post:
  Express Recovery
  EXPRESS HOUSE
  47 Preen Dr
  Middlesbrough
  TS5 8AL