MyNextbase Connect Privacy Policy


This is an important notice regarding their privacy and the way in which Portable Multimedia Limited (referred to as "we", "our" or "us" in this policy) collects and uses your personal data through the mobile app "MyNextbase Connect". We want to be transparent and open with you. Therefore, we encourage you to contact us if you have any questions about this policy or the way in which we use your personal information.

This policy applies to the users of our app, external emergency contacts, as well as third parties in general.We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.

This policy sets out the basis for how we process the personal data we collect about you or provide to us. Please read the following carefully to understand our ideas and practices regarding your personal data and how we will treat it.

For the purposes of applicable data protection laws, the data controller is Portable Multimedia Limited T/A Nextbase, Floor 6, 230 Blackfriars Road, London, SE1 8NW. Our company registration number is 04038169.

Questions regarding this policy should be directed to our Data Protection Officer, who can  be reached at [email protected]. The Data Protection Officer is responsible for compliance with applicable data protection laws as well as this Policy. Any questions regarding the implementation of this Directive, as well as any concerns regarding non-compliance with it, should be addressed to the Data Protection Officer in the first instance.

1.What information about you do we store?

We may collect, store and use personal information about you (referred to as personal data in this Privacy Policy):

App users

  1. Personal contact details such as name, title, email address, telephone number and postal address.
  2. Vehicle data such as registration number and vehicle model.
  3. Contact details of your registered physician including the name and address of the practice.
  4. Medical information such as allergies, prescribed medications, blood type, and diabetes information.
  5. Personal information provided to us by third-party service providers, such as platform providers.

External emergency contacts

  1. Personal contact details such as Your name and phone number.

General

  1. Data provided to us by third-party service providers with whom we work for payment or platform services, for example.
  2. How do we use your personal data and what is the legal basis for doing so?

2. How do we use your personal data and what is the relevant legal basis for doing so?

We will only use your personal information when permitted by law. If we use your personal data, there must be a legal basis for doing so. The following are (some of) the legal bases on which our use of your personal data is based:

  1. If you have given us your consent to do so;
  2. Where we need to perform the contract we have with you or take steps to enter into a contract with you;
  3. If we need to comply with a legal obligation to which we are subject;
  4. Where it is in our legitimate interests (or those of a third party) and your interests and fundamental rights do not outweigh those interests.

In particular, we use your personal data in the following circumstances:

App users

  1. Your contact details – to perform the contract we have with you or to take steps to enter into a contract with you.
  2. Your contact details to provide you with emergency medical assistance – to protect your vital interests if you are unable to give your consent as a result of an accident.
  3. Your contact details to provide you with marketing information about our products and services – where you have given us your consent to do so.
  4. Vehicle data passed on to emergency medical services in the event of an accident – to protect their vital interests if they are unable to give your consent as a result of an accident.
  5. Contact details of a doctor who will be forwarded to the emergency medical service in the event of an accident – to protect their vital interests if they are unable to give your consent as a result of an accident.
  6. Allergy information that is passed on to emergency medical services in the event of an accident – to protect their vital interests if they are unable to give your consent as a result of an accident.
  7. Information about prescribed medications that will be passed on to the emergency medical service in the event of an accident – to protect their vital interests if they are unable to give your consent as a result of an accident.
  8. Information about whether you have diabetes, which will be referred to the emergency medical service in the event of an accident – to protect your vital interests if you are unable to give your consent as a result of an accident.
  9. Other relevant medical information provided that will be passed on to the emergency medical service in the event of an accident – to protect their vital interests if they are unable to give your consent as a result of an accident.
  10. To optimise our app and ensure that content is presented in the most efficient way possible for you and your phone – in pursuit of our legitimate interests (to optimise our content and your experience).

External emergency contacts

Your personal data – to ensure that all users of the My Nextbase Connect mobile app receive the appropriate support in the exercise of our legitimate interests.

General

  1. To administer our app and for internal operations, including troubleshooting, data analysis, testing, research, statistics and surveys – in the exercise of our legitimate interests (to better understand how users interact with our app and to troubleshoot any problems)
  2. To transfer it to third-party service providers – in the exercise of our legitimate interests (by outsourcing for effectiveness and efficiency)
  3. To contact you if we want to use your information for a purpose not set out in this policy – to comply with a legal obligation.

3. What happens if the purpose changes?

We will only use your personal information for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is consistent with the original purpose. If we need to use your personal data for any other purpose, we will let you know and explain the legal basis that allows us to do so.

4. What kind of third parties may we disclose your personal data to?

We require all third parties to respect the security of your personal data and to process it in accordance with the law. For example, when we engage third-party service providers, we do our due diligence to ensure that your personal information is taken as seriously by those providers as it is by us.

We may disclose your personal information to the following types of third parties:

  1. providers of technical support, e.g. related to app development.
  2. Providers who assist us in receiving payments through our app.
  3. Professional advisors such as lawyers and insurance companies.
  4. Emergency services that provide services required for the app.

5. Data retention

How long do we use your personal data?

We will retain your personal information for as long as necessary for the purpose for which it was collected.

We evaluate the appropriate retention period for different data based on its size, amount, nature and confidentiality, the potential risk to you from unauthorized use or disclosure of the data, the purposes for which we use it, the legal requirements for retaining it, and the ability to achieve the purposes in other ways.

App users

  1. If you provided personal data when you first set up the app, all personal data will be stored for as long as you are actively using the app. If we rely on your consent, we will delete your data when you withdraw your consent.

External emergency contacts

  1. We will retain your personal data for the period for which the user who has listed you as an emergency contact is actively using the App without withdrawing their consent.

6. Where we store your personal data

Electronic versions of your personal data are stored on our servers in the UK and Ireland.

If we use third-party service providers to do this, your personal information may also be retained in accordance with their practices and procedures. We require all third parties to respect your personal data and to process it in accordance with the law.

If your data is transferred outside the EEA, we will take steps to ensure that your personal data is adequately protected.

7. Right of access, rectification, cancellation and limitation

Your rights in relation to your personal data

In certain circumstances, you are legally entitled to:

  1. Request access to your personal data (usually referred to as a "data subject access request"). This will provide you with a copy of the personal data we hold about you in order to check whether we are lawfully processing it.
  2. Request correction of the personal data we have. This allows them to correct any incomplete or inaccurate data about you.
  3. Request deletion of your personal data. You can ask us to delete or remove personal data if there is no good reason for continuing to process it. You also have the right to ask us to stop processing your personal data if it is based on a legitimate interest on our part but you wish to object to processing on that basis due to a particular situation.
  4. Request restriction of processing of your personal data. In this way, you can ask us to suspend the processing of personal data about you if, for example, you want to ask us to demonstrate the accuracy of the data or to indicate the reason for processing it.
  5. Request the transfer of your personal data to a third party.

If you wish to review or rectify your personal data, if you wish to request its deletion, if you wish to object to its processing, or if you wish to request its transfer to third parties, please contact our Data Protection Officer in writing using the contact information provided at the beginning of this Privacy Policy.

8. Usually free of charge

There is no fee if you want to access your personal data (or exercise any of your other rights). However, we may charge a reasonable fee if your access request is clearly unfounded or excessive. In these cases, we may also reject your request.

9. What we need from you

We may need to request certain information from you in order to confirm your identity and to secure your right to access personal information (or to exercise your other rights). This is a security measure designed to ensure that personal data is not disclosed to persons who are not authorised to do so.

10. The right to withdraw your consent

In the rare cases where you have given your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent to the relevant processing at any time. If you wish to withdraw your consent, please contact our Data Protection Officer in writing using the contact information provided at the beginning of this Privacy Policy.

If we send you marketing information, you can also change the relevant preferences by clicking on the "unsubscribe" button at the bottom of our marketing emails.

Once we receive a notification of the withdrawal of your consent, we will no longer process your personal data for the purposes to which you originally consented, unless there is another legitimate basis for doing so.

11. What happens if you don't provide personal information?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (e.g., provide you with our products or services) or comply with our legal obligations (e.g., to ensure the health and safety of visitors to our premises).

12. Right to lodge a complaint

Complaints should be directed in the first instance to our Data Protection Officer, who can can be reached at  [email protected] .

If we are unable to resolve the complaint, the supervisory authority for 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. You can also make a call (0303 123 1113) or send an e-mail ([email protected]).

If you are not a resident of the UK, please contact us so that we can provide you with the relevant supervisory authority, if applicable.

13. Changes to this Privacy Notice

We may change, edit, amend, or remove portions of this Privacy Policy at any time, and any changes will be effective immediately.

Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.