MyNextbase Connect Privacy Policy

This is an important notice regarding your privacy and the way in which Portable Multimedia Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data 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 data.

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 the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable privacy legislation, 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 contacted at [email protected]. The Data Protection Officer is responsible for ensuring compliance with relevant data protection legislation and with this policy. 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 Data Protection Officer.

  1. What information do we hold about you?

    We may collect, store and use personal data 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.
    • 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.
    • Personal information provided to us by the third party service providers we work with, for example platform providers.
    • Location-related information data to scan your dash cam for connection, check for Emergency SOS eligibility, and send your location using Emergency SOS in the case of an incident.

    Third Party Emergency Contacts

    • Personal contact details such as your name, and telephone number.

    Generally

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

  2. 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:

    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.
    • 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).
    • Your location data is used for your dash cam for connection – to perform the contract with you.

    Third Party Emergency Contacts

    • 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, data 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.

  3. 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.

  4. 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.

  5. Data 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 data 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 data 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.

  6. Where we store your personal data

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

  7. Rights of access, correction, erasure and restriction

    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 “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.

    If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.

  8. 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.

  9. 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.

  10. 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 Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.

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

    Where we are providing you with marketing information via MyNextbase connect mobile application , you can change your marketing preferences by opting out in the Settings within the mobile application.

    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 we have another legitimate basis for doing so.

    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 we have another legitimate basis for doing so.

  11. 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).

  12. Right to complain

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

    If we cannot resolve the compliant, 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 ([email protected]).

    In the event that you are located outside of the UK we welcome you to contact us so that we can provide you with the relevant governing board details where appropriate.

  13. 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.