Intelligent Instructor Ltd respect your privacy and are committed to protecting your personal information.
In this privacy notice we will outline how we look after your personal information whether it is collected in person, over the phone or on our website/s and what your rights are and how the law protects you.
The purpose of this privacy notice
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.
Who We Are
Intelligent Instructor Ltd is the controller and responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Intelligent Instructor Ltd
Name or title of data privacy manager: Richard Storrs
Email address: [email protected]
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 11.02.2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
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.
Information we may hold about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data
This includes data relating specifically to your identity, such as your first and last name.
- Contact Data
This includes data relating to how you may be contacted, such as your address, email address and telephone numbers.
- Financial Data
This includes data relating to your means and methods of payment, such as your bank account and payment card details.
- Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your 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.
- Profile Data
This includes the data that we receive when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data
This includes information about how you use our website, products and services.
- Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share 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 Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
In other words, where we require details from you in order to provide you with your chosen service/s, if you do not provide us with the necessary details then we will not be able to provide the services you have requested or booked with us.
In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your request or we may have to cancel your arrangement, in which case we will treat this as a ‘cancellation by you’ in accordance with our Terms & Conditions.. We will notify you if we are unable to process a request or are required to cancel an arrangement for this reason.
How we collect your data
We use different methods to collect data from and about you including through:
- When you engage directly with us
You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o completing an application form;
o subscribe to our magazine, e-newsletter or other alerts;
o request marketing to be sent to you;
o enter a competition, promotion or survey;
o give us some feedback;
- Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
Like many websites we receive ‘automatic information’ through cookies. We use this information to provide a personalised experience on our site and a better service tailored to suit you.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our systems to recognise your browser. Cookies from First Car website are safe and allow us to personalise our site for each user.
The main purpose of our cookies is to identify you when you visit our website. Each time your browser requests a web page from our server, the browser sends the information in the text file back to the server and lets the server know that you have returned to that web page.
Cookies help us to remember who you are and what your preferences are. Next time you return, we can fill in any questions that you have already answered. The more you tell us about yourself, the more we can help to find information or products you want.
You can disable cookies – simply go to the help menu on your browser bar to find out how. If you do leave cookies turned on, be sure to sign off when you finish using a shared computer. If you do not accept incoming cookies then the performance of our website on your system will not be to full standard or our website may not serve at all.
- When you give it to us indirectly
We may receive personal data about you from various third parties as set out below:
o Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
How we use your personal information
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:
- To enable us to provide you with a service that you have requested
- To administer membership/subscription records;
- To maintain our own accounts and records
- To inform you of news, events, activities and services running
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.
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 enable you a chance to win competitions with us, including the annual win a car competition||1. Identity
3. Marketing & Comms
|Performance of a potential ‘Contract’ with you and where marketing permissions are given, ‘Consent’ to send you marketing communication|
|To send you our weekly email newsletter||1. Contact||From your given ‘Consent’|
|To manage our relationship with you which will include:
Asking you to leave feedback or take a survey.
4. Marketing and Communications.
|1. Performance of a ‘Contract’ with you;
2. Necessary to comply with a ‘legal obligation’;
Necessary for our ‘legitimate interests’ (to keep our records updated and to study how customers use our products/services).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||1. Identity;
|1. 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);
2. Necessary to comply with a legal obligation.
To enhance and customise the user experience
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||1. Technical
|Necessary for our legitimate interests (to define 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)|
Data Retention Period
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.
For all the purposes for which we will use your personal data outlined in the table above, we will retain your personal data until you request for it to be deleted, or anonymise your contact record after 12 months of inactivity with Intelligent Instructor Ltd.
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
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:
- When signed up to our newsletter, you have the opportunity to unsubscribe using the link at the bottom of email newsletters sent to you, or by contacting us directly.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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).
You will receive marketing communications from us only when you have given us your specific consent to receive such communications.
It is not our usual policy to share your personal information with any company outside the Intelligent Instructor Ltd for marketing purposes, but if we did we would only do so with your express opt-in consent.
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.
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.
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.
How we disclose 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 4 above.
- External Third Parties as set out in the Glossary.
- 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.
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.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to
your personal data: –
- The right to request a copy of your personal data which Intelligent Instructor Ltd hold about you;
- The right to request that Intelligent Instructor Ltd corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for the Intelligent Instructor Ltd to retain such data;
- The right to withdraw your consent to the processing at any time
- The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
- The right to lodge a complaint with the Information Commissioners Office.
How we secure your data
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.
- Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service 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
- 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.
- 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.
the individual has given clear consent for you to process their personal data for a specific purpose.
- Vital Interest
processing is necessary in order to protect the vital interests of the data subject or of another natural person
- External Third Parties
- Service providers acting as processors based inside and outside of the EU who provide the technology to pass and store your information, to send relevant communications to you, process a financial transaction.
- Service providers acting as processors based inside and outside of the EU who provide technical support and development for our website
- Professional advisers acting as processors including data analyst, lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.