DATA PROTECTION & PRIVACY POLICY

HGV Training Services Ltd privacy notice

HGV Training Services Ltd is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and use our services and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy notice

1. This privacy notice aims to give you information on how HGV Training Services Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletters, enrol on one of our programmes or sign up to attend one of the events that we organise.
2. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

3. This privacy notice is issued on behalf of HGV Training Services Ltd so when we mention “HGVC”, “we”, “us” or “our” in this privacy notice, we are referring to HGV Training Services Ltd. HGV Training Services Ltd is the controller and responsible for this website. We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Registration number ZA748844.
4. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact us using the details set out below.

Full name of legal entity : HGV Training Services Ltd

Email address : info@hgvc.co.uk

Postal address : HGVC, Alpha House, Regis Road,London, NW5 3EW

Changes to the privacy notice and your duty to inform us of changes

5. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
6. In turn, we will keep you updated with any changes to this privacy notice.

Third-party links

7. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

8. 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).
9. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows :
• Identity Data includes first name, middle name, last name, username or similar identifier, title, date of birth, gender, National Insurance Number
• Driving licence Data: driving licence number, CPC hours, driving licence categories held.
• Contact Data includes email address, telephone numbers, and address.
• Training data: training types, dates, locations, outcomes, training logs.
• Technical Data includes internet protocol (IP) address, your login 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 this website.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
10. We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Training Data to calculate the training pass rates. However, if we combine or 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.
11. We will not collect special categories of data from you – such as personal data concerning your race, political opinions, religion, health, or sexual orientation – unless you have chosen to provide that type of personal data to us as part of registration for a programme, service, or research project. Where collected the use of such special category data will be made clear to you at the time of capture.
12. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

13. How is your personal data collected?

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

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
• Register to use our site
• Subscribe to our services, newsletters or publications;
• Download content such as reports;
• Enrol on a training programme;
• Sign up to attend an event that we are organising;
• Request marketing to be sent to you;
• Take part in any discussion forums that we host; or
• Give us some feedback;
• Participate in our market research.
14. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
15. Third parties or publicly available sources. We may receive personal data about you from various third parties, including those set out below :
• (a) analytics providers such as Google;
• (b) other third parties such as, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, search information providers, credit reference agencies
16. How we use your personal data

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.
• 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.
• Where we need to comply with a legal or regulatory obligation.
17. See below to find out more about the types of lawful basis that we will rely on to process your personal data.
18. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
19. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client as part of your enrolment on a training programme or your signing up to attend an event	(a) Identity (b) Contact	Performance of a contract with you
To deliver information, reports, newsletters and programmes that you have signed up to receive	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To manage our relationship with you which will include : (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, programmes, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our programmes, events and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about programmes, events or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (to develop our services and grow our business)

20. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

21. Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

22. You will receive marketing communications from us if you have requested information from us or purchased or received services from us (including enrolling on a programme or attending an event) and, in each case, you have not opted out of receiving that marketing.
23. Third-party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the Tech Nation group of companies for marketing purposes.

24. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of enrolling onto a programme, registering for an event, or submitting a form on the website.

If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future

25. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

26. Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

27. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
28. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 19 above.

• Subcontractors to HGV Training Services Ltd where it is required as part of the service delivery.
• CRM platforms such as Salesforce
• Manpower UK if your contract with us requires recruitment services.
• 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 notice.
• Law enforcement, government, courts, dispute resolution bodies, our regulators, auditors, and any party appointed or requested by our regulators to carry out investigations or audits of our activities.
• Other parties involved in any disputes, including disputed transactions.
• Anyone who provides instructions or operates any of your accounts on your behalf, e.g. Power of Attorney, solicitors, intermediaries, etc;
• Our card processing supplier(s) to carry out credit, fraud and risk checks.
• Anybody else that we’ve been instructed to share your information with by either you, a joint account holder.
29. Third Parties

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.

30. International Transfers

We do not transfer the data outside the UK. All the data is stored in the UK based data centres.

31. 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.

32. Data Retention

How long will you use my personal data for?

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.

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you.

33. In some circumstances you can ask us to delete your data: see the YOUR LEGAL RIGHTS section below for further information.
34. 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.
35. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read the section called YOUR LEGAL RIGHTS below to find out more about these rights

If you wish to exercise any of your legal rights, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

36. 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 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.

37. Time limit to respond

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.

Glossary

Lawful Basis

38. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
39. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
40. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
41. Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

42. Delete your HGVC Account:

When you delete your account, your email address, mobile number, and all your personal data will be deleted.

To request the account deletion kindly follow the below steps:

1. Login into HGVC application with your credentials.
2. Navigate to Account Page from bottom Nav Bar
3. Click on 'Delete Account' on the Account Page.
4. Click 'CONFIRM' to delete your account so that your account will be permanently deleted.