Privacy Policy

Wondle is committed to protecting the privacy and security of your personal data. This privacy policy describes how we collect, use and protect your personal data when you visit our website (regardless of where you visit it from), communicate with us or use our platform. It also tells you about your rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. The Glossary sets out the meaning of terms used in this privacy policy.

1 Important information

This privacy policy aims to give you information about how we collect and process your personal data through your use of this website.

We are Wondle Limited, a private limited company registered in England and Wales under company number 13912851 with registered office at 179 Park Lane, Poynton SK12 1RH, and we are the controller for personal data which is collected about you when you visit our website, communicate with us or use the Wondle platform.

Our website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy works alongside the other notices that apply to our platform (including the Wondle Terms of Use and is not intended to override them. It is important that you read this privacy policy together with any other privacy notices 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.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our us, either:

by email to: support@wondle.io ; or

by post to: Wondle, 179 Park Lane, Poynton SK12 1RH

You have the right to make a complaint at any time to the ICO (www.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 policy

We keep our privacy policy under regular review. This version was last updated in September 2022.

Your duty to inform us of changes

It is important that the data we hold about you is accurate and current, so please keep us informed of any changes to your personal data.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy notices. You should, therefore, also read their privacy notices to understand what personal data they collect about you and how they use it.

2 The data we collect about you

We may collect, use, store and transfer the types of personal data about you listed below:

identity data	first name, last name, preferred title, username or similar identifier, and date of birth
contact data	billing address, home address, email address and telephone number
financial data	bank account and payment card details
marketing and communication data	your preferences in receiving marketing from us and from third parties, and your communication preferences
account data	your username and password, information about the vehicle(s) for which you request us to provide the services (including any personal data contained in the photos, videos or other information you submit to us through the platform), and any personal data contained in the reports we prepare for you, together with other account preferences, and other personal information you provide to us in connection with the administration or use of your account
technical data	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 our website
transaction data	details about payments to and from you and other details of products and services you have purchased from us

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) or any information about criminal convictions and offences.

Failure to provide personal data

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.

3 How personal data is collected

We collect personal data in the following ways:

direct interactions	you may provide personal data when you complete online forms, request us to provide the services, create a user account, join our mailing list, or otherwise or correspond with us (by post, phone or email)
automated technology	we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our cookie policy for further details.
publicly available sources	we may collect personal data from publicly availably sources such as Companies House and the Electoral Register and credit reference agencies, based inside the EU
third parties	we may receive personal data from analytics providers (such as Google), the suppliers we use, including the provider of the AI solution we use to generate our reports, the vehicle leasing companies and third-party repair providers we may interact with on your behalf, our electronic payment service provider – currently Stripe Payments Europe, Limited – and potentially from third parties that we use to provide services in connection with our website.

4 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:

to perform the contract we are to enter into or have entered into with you;
to comply with a legal obligation; and
where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We have set out below specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity	Type of data	Lawful basis for processing
to register you as a new customer	identity & contact	to perform our contract with you
to deliver services you request us to provide (including by interacting on your behalf with third parties including approved repair providers, manage payments, fees and charges and debt recovery	identity, contact, financial, transaction and marketing & communications	(i) to perform our contract with you; (ii) as necessary for our legitimate interest in recovering debts due to us.
to manage our relationship with you, notifying you about changes to the Wondle Terms of use or this privacy policy, and asking you to leave a review or take a survey	identity, contact, profile & marketing & communications	(i) to perform our contract with you (ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and analysing 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)	identity, contact & technical	(i) as necessary for our legitimate interests in 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 (ii) as necessary to comply with any legal obligations
to deliver relevant website content/ advertisements to you and measure or understand the effectiveness of our advertising	identity, contact, profile, usage, marketing & communications & technical	as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
to use data analytics to improve our website, products/services, marketing, customer relationships and experiences	technical & usage	as 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
to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers	identity, contact, technical, usage & profile	as necessary for our legitimate interests to develop our products/services and grow our business

We generally only rely on consent as a legal basis for processing your personal data to send email and SMS marketing communications and you have the right to withdraw your consent to such marketing communications at any time by contacting us.

Please 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 information.

Marketing

We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased goods or services from us, and/or if you consent to marketing at the time we collect your personal data, and only if you have not subsequently opted out or withdrawn your consent (unless we have another basis to send you the marketing communications).

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

How to opt out

You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to marketing at any time by contacting us, or by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

Change of purpose

We will only use your personal data for the purpose that we originally collected it for, 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

5 Disclosure of your personal data

We may share your personal data with third parties, each of which may receive the personal data as a processor or, where applicable, as an independent controller of your personal data. Further details of these third parties are set out below.

service providers	including: · the provider of the AI solution we use to generate our reports, and the cloud hosting services such as AWS and Azure they use to host machine learning models and store customer data at locations in the United Kingdom and the European Economic Area (EEA); · our electronic payment service provider – currently Stripe Payments Europe, Limited; · and potentially other third-party service providers that we use to provide website support and maintenance services
Third parties we interact with on your behalf	acting as processors or independent controllers as applicable, and including the vehicle leasing companies and third-party repair providers we may interact with on your behalf
professional advisors	acting as processors or independent controllers as applicable, including 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 or independent controllers as applicable, based in the United Kingdom who may require reporting of processing activities in certain circumstances
third parties involved in relevant transactions	third parties whom we may choose in connection with the sale, transfer or merger of all or part 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 policy

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. They can only process your personal data for specified purposes and in accordance with our instructions.

6 International transfers

We use external third parties based outside the United Kingdom and the European Economic Area (EEA), and their processing of your personal data may involve a transfer of data outside the United Kingdom and the EEA. Whenever we transfer your personal data out of the United Kingdom and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at leastone of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO;
we use specific contracts approved by the ICO which give personal data the same protection it has in Europe with our services providers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7 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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.

We have procedures in place 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.

8 Data retention

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

9 Your legal rights

You have certain rights in certain circumstances under data protection law. These are described below. If you wish to exercise any of your rights, please contact us.

You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

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.

You have the following legal rights in relation to your personal data:

access your data	you can ask for access to and a copy of your personal data and can check we are lawfully processing it
correction	you can ask us to correct any incomplete or inaccurate personal data we hold about you
erasure	you can ask us to delete or remove your personal data where: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object (see below); (c) we may have processed your information unlawfully; or (d) we are required to erase your personal data to comply with local law. We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
object	you can object to the processing of your personal data: (a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; (b) 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 and in such circumstances, we can continue to process your persona data for such purposes.
restrict processing	you can ask us to us to suspend or restrict the processing of your personal data, if: (a) you want us to establish the accuracy of your personal data; (b) our use of your personal data is unlawful, but you do not want us to erase it; (c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it.
request a transfer	you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.
withdraw your consent	you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.

10 Glossary

aggregated data	information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject
controller	a body that determines the purposes and means of processing personal data
data subject	an individual living person identified by personal data (which will generally be you)
personal data	information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data
processor	a body that is responsible for processing personal data on behalf of a controller.
special categories of personal data	information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.
ICO	Information Commissioner’s Office, the UK supervisory authority for data protection issues.