MyNextbase Connect Privacy Policy

This is an important notice regarding your privacy and the way in which Portable Multimedia Limited trading as Nextbase (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal information through our ‘MyNextbase Connect’ Phone Application. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal information.

This policy applies to our app users, third party emergency contacts and third parties generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.

This policy sets out how we will process your personal information. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

For the purpose of applicable privacy legislation, the information 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 Compliance Manager who can be contacted at [email protected]. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Compliance Manager.

What information do we hold about you?

We may collect, store and use information about you (referred to throughout this privacy policy as personal information.:

Application Users

Personal contact details such as your name, title, address, telephone number and e-mail address.

Information submitted to the Emergency SOS (ESOS) feature of the MyNextbase Connect App is held on your phone. In the event of your Dashcam detecting that you have been in an accident, are unable to respond, and where you have supplied the information, the following personal information will be sent from the App on your phone via Nextbase to the Emergency Services

The current 3m² location of your mobile phone and / or camera
Vehicle information such as your registration number and vehicle model.
Contact details of your registered medical professional including name and surgery address
Medical information such as your allergies, prescribed medications, blood type and diabetes details.

The personal information entered onto ESOS will not be stored by Nextbase and will not be used by Nextbase. Your personal information is protected on a secure system during the transfer.

Generally

Information provided to us by third party service providers we work with, for example, payment service or platform providers.

How will we use your personal information and what is the legal ground we rely on for doing so?

We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:

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.

More specifically, we will use your personal information in the following circumstances:

Road Safety Club Membership

Video files and meta data (date, time and GPS) from your dashcam that we will extract and redact when we have received a data customer request – in line with the informed and fully revocable consent you have provided us.
Video files and meta data (date, time and GPS) from your dashcam that you have chosen to submit to us for the purposes of forwarding to appropriate authorities – in line with the informed and fully revocable consent you have provided us.
We do not need your contact details to become a member of Road Safety Club. The consent you provide us will be linked to your dashcam only. Please see Application Users for further details of where your contact details may be required.

Application Users

Your contact details – to perform the contract with you or to take steps to enter into a contract with you.
Your contact details to provide you with emergency medical assistance – to protect your vital interests where you are not able to give consent as a result of an accident.
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.

Personal information that you load to ESOS is not retained by Nextbase.

The following information will be automatically transferred from your phone via Nextbase, to parties identified when your Dash Cam detects that an accident has occurred, and you do not respond.

Only the personal information that you add to the App will be transferred.

Information will be transferred using a secure system.

Personal information from the ESOS feature will not be retained by Nextbase after a transfer has occurred.

Current 3m² location of your phone and/or camera – to protect your vital interests where you are not able to do so as a result of an accident.
Vehicle Information to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
Medical professional contact details to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
Allergy details to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
Prescribed medication information to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
Details regarding whether or not you suffer from Diabetes to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
Details of any other relevant medical information provided to be passed on to the emergency services in the event of a collision – to protect your vital interests where you are not able to give consent as a result of an accident.
To improve our application to ensure that content is presented in the most effective manner for you and your phone – in pursuit of our legitimate interests (to improve our content and your experience).

Third Party Emergency Contacts

In the event of an accident, your Dashcam is able to send a message to the third party personal contacts you have selected in ESOS.

Your personal details – in pursuit of our legitimate in ensuring that any App User receives the relevant assistance during use of the ‘My Nextbase Connect’ phone application.

Generally

To administer our application for internal operations, including troubleshooting, information analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our application and solve any issues it may have).
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.

What happens if there is a change of purpose?

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Which type of third parties might we share your personal information with?

We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.

We may share your personal information with the following types of third parties:

Technical support providers, for example, assisting with our application development.
Providers assisting us with receipt of payments via our application.
Professional advisers such as lawyers and insurance companies.
Emergency services to provide services necessary for the application.

Information retention

How long will we use your personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.

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.

Application Users

If you have provided personal information during the initial set up of the application, all personal information will be stored, for as long as you remain an active user of the application or where we rely on consent, we will delete your information where you withdraw your consent.

Third Party Emergency Contacts

We will keep your personal information so long as the application user who has listed as you an emergency contact remains an active user of the application or withdraw your consent.

Where we store your personal information

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

Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.

Where your information is transferred outside of the UK, we will take steps to ensure your personal information is adequately protected.

Road Safety Club Data

Video files submitted to Nextbase as part of our Road Safety Club program will be stored on servers located in the UK.

Rights of access, correction, erasure, restriction, portability and objection

Your rights in connection with your personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (known as a “information 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 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.

If you want to please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.

You can also register a data query or takedown request by following the process at https://nextbase.co.uk/data-inquiry-gateway

No fee usually required

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.

What we may need from you

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.

Right to withdraw consent

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 Information Protection Officer in writing or by telephone using the contact details set out at the beginning of this privacy policy.

Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless required by law.

What happens if you fail to 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 (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).

Right to complain

In the first instance, please direct complaints to our Information Protection Officer who can be contacted at [email protected].

If we cannot resolve the compliant, you can complain to the regulator. The regulator in the UK 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 ([email protected]).

Our representative in the EU is Data Rep, located at 77 Camden Street Lower, Dublin D02 XE80, Ireland, https://www.datarep.com/ You can contact Data Rep on email: [email protected] or their online portal at www.datarep.com/nextbase

In the event that you are located outside of the UK and EU we welcome you to contact us so that we can provide you with the relevant supervisory authority details, where appropriate.

Changes to this privacy notice

We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.

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