Privacy policy

1. Important Notice

This is the Privacy Policy or Notice (the "Privacy Notice") of Glasscare Limited t/a Windscreen Pro, a company registered in England and Wales with company number: 03749924 and whose registered Office is at Fleet House, Alan Stanton Ltd, Unit 3, 1 Armstrong Road, Benfleet, Essex, United Kingdom, SS7 4FH
("we", "us" or "our") and sets out how we collect and process your personal data.

This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data. This Privacy Notice relates to personal information that identifies "you" meaning customers or potential customers, individuals who browse our website and individuals outside our organisation with whom we interact. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

We refer to this information throughout this Privacy Notice as "personal data" and section 3 sets out further detail of what this includes.

Please read this Privacy Notice to understand how we may use and treat your personal data.

This Privacy Notice may vary from time to time so please check it regularly. This version of this Privacy Notice was first published on 21 May 2018 and has not been updated since.

2. How to contact us

For the purposes of relevant data protection legislation, we are a controller of your personal data and as a controller we use the personal data we hold about you in accordance with this Privacy Notice.

If you need to contact us in connection with our use or processing of your personal data, or to gain access to it, please contact:

If you need to update your preferences on how Glasscare will contact you, please email: info@sicp.co.uk

3. Categories of Personal Data we collect

The categories of personal data about you that we may collect, use, store, share and transfer are:

• Individual Data. This includes personal data which relates to your identity, such as your first names, last name, username or similar identifier, title, vehicle registration number (VRN), vehicle identification number (VIN), vehicle insurance and fleet membership details and your contact details such as your billing address, appointment address, email address and telephone numbers;

• Account and Profile Data which includes personal data which relates to your account or profile on our website or app, such as purchases or appointments made by you, your preferences, feedback and survey responses;

• Advertising Data. This includes personal data which relates to your advertising preferences.

• Information Technology Data. This includes personal data which relates to your use of our website, such as your login data, traffic data, weblogs and other communication data, 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 our website;

• Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud;

• Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you and other details of products and services you have purchased from us;

• Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations;

• Market Research Data. This includes personal data which is gathered for the purposes of market research.

We may also create Personal Data about you. For example, if you contact us by telephone to enquire about the way in which we have provided our service to you, we may make a written record of key details of the conversation so that we can take steps to address your enquiry and any issues you may have identified to us.

We also obtain and use certain aggregated data, such as statistical or demographic data for any purpose ("Aggregated Data"). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. Where we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

4. The sources from which we obtain your personal data

We obtain your personal data from the following sources:

• Directly from you, either in person (at our locations or otherwise), via our website or by telephone or via hand held electronic devices used by our technician population. This could include personal data that you provide when you:

1. place an order for our products or services;

2. log into your account through our website;

3. communicate with us via platforms such as Web Chat, SMS Chat or smart speakers;

4. submit a photo of your vehicle glass damage;

5. enter into a competition or promotion;

6. complete a survey from us or give us feedback;

7. request information on our products and/or services;

8. request other marketing to be sent to you;

• Automated technologies, such as CCTV and other audio and visual recording systems, cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your computer and phone equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites employing our cookies.
  Third parties, such as:

1. insurers, insurance brokers and vehicle leasing organisations with which you have a contract, where those organisations have shared your information with us to assist us in providing a service to them and to you;

2. analytics providers such as Google Analytics, IBM Cognos and MS PowerBI

3. customer feedback collection service providers, such as Qualtrics, Qualaroo and ENGINE (please see their Privacy Policy on how your data is managed by them);

4. search information providers, such as Google and Bing;

5. providers of technical, payment and delivery services, such as WorldPay and Localz;

6. data brokers, such as Experian;

7. advertising network and information providers;

8. providers of social media platforms (such as Facebook, Twitter and Instagram), for example where you share our content through social media or “like” us on Facebook or follow or tweet about us on Twitter; and

• Publicly available sources, such as:

1. Companies House;

2. HM Land Registry; and

3. DVLA

Please note that the list of examples above is not intended to be exhaustive and represents a description of the kinds of sources of information we rely upon.

5. How we use your personal data & our basis for using it

We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data:

Purposes for which we process your personal data	Categories of personal data	The basis on which we can do this (this is what the law allows)
To register you as a new customer and process your order	Individual Data; Economic and Financial Data; Account and Profile Data.	The processing is necessary To Perform a contract with you; and Our legitimate interest in the provision of goods and services to our customers.
In order to perform our contractual obligations to you. This would include: processing and performing any service booked by you; sharing information with any insurer or broker or leasing company or other entity connected to the basis on which you have instructed our work (such as your employer if you are using a company car); making or receiving payments, fees and charges; and collecting and recovering money owed.	Individual Data; Economic and Financial Data; Account and Profile Data.	The processing is necessary To Perform a contract with you; and Our legitimate interest in recovering debts owed to us.
In order to comply with our own legal obligations, e.g. health and safety legislations, or to assist in an investigation (e.g. from the police)	Individual Data; Economic and Financial Data; Information Technology Data; Sales Data; Account and Profile Data.	The processing is necessary for us to comply with the law
In order to use your personal data in life or death situations and there is no time to gain your consent (e.g. in the event of an accident and we have to give your personal details to medical personnel).	Individual Data	The processing is necessary in order to protect the vital interests of an individual.
In order to manage our relationship with you including: to send you important notices, such as communications about changes to our terms and conditions and policies (including this Privacy Notice); to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and to send you information you have requested; to deal with your enquiries; and to ask you to leave a review or feedback on us.	Individual Data; Account and Profile Data. Economic and Financial Data; Information Technology Data;	The processing is necessary To Perform a contract with you; and Our legitimate interest in the provision of goods and services to our customers.
In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations.	Individual Data; Account and Profile Data. Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for our legitimate interest in provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; and necessary to comply with the law.
In order to improve the way in which we work in the future (including but not limited to improving our own system of quality checks); and to make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our communications and advertising.	Individual Data; Advertising Data; Account and Profile Data; Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for our legitimate interests to study how our customers use our products/services, to develop our products and services and ensure our communications and marketing are relevant to you, to grow our business and to inform our communication and marketing strategy.
For internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of our communications, promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences.	Individual Data; Advertising Data; Account and Profile Data; Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To communicate with you about our services and administer your participation in, surveys, special events, programs, promotions, any prize draws or competitions.	Individual Data; Advertising Data; Account and Profile Data; Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for performance of a contract with you; and/or necessary for our legitimate interests to promote/improve our business
To sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers.	Individual Data; Advertising Data; Account and Profile Data; Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
The processing is necessary for our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.	Individual Data; Advertising Data; Account and Profile Data; Economic and Financial Data; Information Technology Data; Sales Data; Audio and visual Data.	The processing is necessary for our legitimate interests in protecting our business and property and recovering debts owed to us.

We may like to use your personal data for a variety of different purposes and in that case, we will obtain your prior consent before we do so. For example:

• where we would like to use your image or a photo of you in our promotional materials;
• where we or our carefully selected third parties have new products and services which we think you will be interested in.

The legal basis of consent is only used by us in relation to processing that is entirely voluntary - it is not used for processing that is necessary or obligatory in any way, including where we are using the information for performance of a contract with you or pursuant to our legitimate interest. Consent is further obtained, where required, to use cookies for marketing purposes.

We will only send you marketing we believe is beneficial and specifically relevant to you, or where you have given your consent (if relevant). You can change your marketing preferences at any time for what you receive from us, and how you receive it by using the contact details set out in paragraph 2.

You may at any time withdraw the specific consent you give to our processing your personal data. If you decide unsubscribe from marketing communications, we will action this within our systems as soon as possible, legally we are entitled to one month to process a data subject right request. Please be aware that you may still receive non-marketing related messages and other important service information. We may also ask you to confirm or update your marketing preferences if there are changes in law, regulation, or business strategy or structure where lawful to do so.

Please note even if you withdraw consent for us to use your personal data for a particular purpose, we may continue to rely on other bases to process your personal data for other purposes.

6. Who receives your personal data

We may disclose your personal data to:

• our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices, such as Worldpay, which processes your card payments on our behalf and Localz (which track and communicate appointment times to you); any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
• our group companies and affiliates or third party data processers who we may need to contact in relation to any query that you may raise with us about the service we will or have provided to you;
• our insurance and vehicle fleet management partners and other third parties involved in the basis of your instruction to us, such as an insurance broker or your employer;
• our customer feedback collection service partners;
• HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
• external professional advisers, such as accountants, bankers, insurers, auditors and lawyers;
• law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
• third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
• third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;

7. Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings, or a person who may meet us when we work on your vehicle or who may assist you in discharging your payment obligations to us) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

8. Accuracy of your personal information

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you.

Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us.

We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us or permit us to retain through failing to notify of any changes to your personal information.

9. Transfers of your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, the provision of support services or data analysis that will assist us in improving our services to you and others in the future. By submitting your personal data to us, you agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

10. How long we will store your personal data for

We will store your personal data for the time period that we believe is appropriate in accordance with our data retention policy. In addition, our retention of data allows us to support recalls (for example, by vehicle and product manufacturers) of vehicles. We keep the length of time that we hold personal data under review. Those reviews take place annually.

11. Contractual or Statutory requirements on you to provide personal data

In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.

It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform our service to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so and that information is incorrect.

12. Your rights in relation to your personal data

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data, you may have a number of rights in connection with the processing of your personal data, including:

• the right to request access to your personal data that we process or control;
• the right to request rectification of any inaccuracies in your personal data or, after taking into account the purposes of our processing, to request that incomplete data is completed;
• the right to request, on legitimate grounds as specified in law:

  1. erasure of your personal data that we process or control; or

  2. restriction of processing of your personal data that we process or control;

• the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
• the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
• the right to lodge complaints regarding the processing of your personal data with the Information Commissioner's Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

13. Links to other websites

This policy only applies to us. If you link to another website from our website, you should remember to read and understand that website's privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third-party websites.

Date: 26th September 2022