ANYVAN PRIVACY POLICY

Hello! If you are reading this, then you care about privacy – and your privacy is very important to us. The purpose of this Privacy Policy is to give you a clear explanation about how we collect and process your personal information through browsing or using our website www.anyvan.com (“Website”), or our ‘partner’ app (“App”). It is important that you read this Privacy Policy together with any other privacy policy, including our cookies policy www.anyvan.com/cookies (“Cookies Policy”), or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information. This Privacy Policy supplements our other policies and is not intended to override them.

This Privacy Policy has been prepared in accordance with the Data Protection Act 2018 which implements the General Data Protection Regulation (or such UK legislation intended to replace or supersede it) (“Data Privacy Laws”). Defined terms used in the Privacy Policy have the meanings set out in the Data Privacy Laws.

Our transport partners (“Transport Partners”) and third-party or sub-contracted drivers (“Drivers”) should also read the privacy notice by following the link at the end of this policy.

Who we are and how to contact us

We are AnyVan Limited of 5th Floor, The Triangle, 5-17 Hammersmith Grove, London W6 0LG and our company registration number is 06837274 (“AnyVan”). References to “we”, “our” or “us” means AnyVan. We are a delivery, transportation, and storage services company. We are the controller of your data. This means that we are responsible for deciding how we collect, store, and use personal information about you.

What data we collect

Personal data is any information that tells us something about you whether directly or indirectly identified or identifiable as an individual. We may collect and use the following personal data about you.

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, your image (be that photographic or video) and vehicle registration/licence plate.
• Contact Data includes residential addresses, property ownership information, relevant contact addresses, email address and telephone numbers.
• Financial Data includes bank account, payment card details and information to enable us to undertake Money Laundering and Terrorist Financing electronic checks on you.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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.
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Call Data includes recording of all calls made with the AnyVan agents.

If you provided personal data of other people for the purpose and fulfilment of a collection and/or delivery, it is your responsibility to notify these people that their data is/was provided to AnyVan.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 treat the combined data as personal data, which will be used in accordance with this privacy policy.

This personal data is required to provide our services to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing services to you.

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). Nor do we collect any information about criminal convictions and offences.

How do we collect personal data

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, such as requesting a quote, or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• contact us through social media;
• request marketing to be sent to you;
• enter a competition;
• promotion or survey;
• give us some feedback;
• contact us via Whatsapp;
• contact us via sms;
• speak with us on the telephone and we record the call;
• make a complaint;
• Automated technologies or interactions. As you interact with our website, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.

Identity and Contact Data from:

• companies providing commercially available data who may be based inside the EU such as TwentyCi or Facebook (based outside the EU);
• from third party portals through which you request the AnyVan services;
• from third party portals through which you request services that we provide (such as AWIN);
• publicly available sources such as social media sites, including Facebook, YouTube and LinkedIn (based outside the EU), Companies House, HM Land Registry and the Electoral Register (based inside the EU).

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks such as Google based outside the EU;
• search information providers such as Google based outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Checkout, Stripe or Adyen who may be based outside the EU.

How we use 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 obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To register you as a new Customer, Transport Partner or Driver and provide services to you.	For the performance of our contract with you or to take steps at your request before entering into a contract.
To manage our relationship with you which will include: Updating and enhancing customer records Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers, transport partners and drivers use our products/services)
To assist in arranging or maintaining any insurance coverage that you, and other users, may require, managing risk or obtaining professional advice.	For the performance of our contract with you or to take steps at your request before entering into a contract.
Conducting checks to identify our customer and verify their identity. Screening for financial and other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, range of services or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
To record telephone calls both incoming and outgoing	Performance of a contract with you Necessary for our legitimate interests (to train staff and maintain high levels of services)
To administer and protect our business, this website and App (including troubleshooting, data analysis, testing, system maintenance, data backups, support, reporting and hosting of data)	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) Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study 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	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)
Marketing our services to: existing and former customers; third parties who have previously registered with us or expressed an interest in our services; third parties with whom we have had no previous dealings	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We will hold your personal data on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide which we feel you might find useful from time to time. You can opt out of receiving this information at any time.

If you would like to opt-out of:

• emails, except those that relate to your booking, you can do so by clicking “Unsubscribe” on the footer on any email; or
• direct marketing, you can do so by logging into your account and clicking “Unsubscribe from marketing emails” on your profile page.

Call recording

We may record any incoming or outgoing calls handled by the AnyVan support team (or transferred to any other department), and any call recordings may be used as follows:

• to monitor call quality;
• to train and develop AnyVan staff;
• to keep a record of what is said about an event or complaint;
• to review and develop our processes to better support our users and check for any mistakes; and
• to prevent, detect and investigate any possible fraud.

If your call is being recorded, you will hear a pre-recorded message stating this before connecting to a member of the AnyVan support team and directing you to this Privacy Policy. The recording starts when you hear a beep and ends automatically when the call ends or when the call is transferred externally.

If you do not want your call to be recorded, please tell the person you are speaking to at any time that you wish the recording to be stopped.  Call recordings are only accessed by members of staff at AnyVan. If you would like a copy of any call recording, you can submit a request in writing to privacy@anyvan.com.

Call recordings will be securely stored for 12 months after the call was made and will be managed in accordance with Data Privacy Laws.

Who we share your personal data with

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers (where possible) to ensure they can only use your personal information to provide services to us and to you. These will include but will not be limited to:

• If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their adviser. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in the privacy policy
• We will share personal data with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
• We may share an encoded version of your personal data to third parties such as Facebook and google to enable these third parties to display AnyVan ads when you visit their websites.
• We may share your personal information with any person working within our group companies (AnyVan, AnyVan Business,  AnyVan Storage) on a need-to-know basis to ensure we are able to perform our obligations to you.

We routinely share personal data with:

• Our insurers and/or professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims;
• Transport Partners and Drivers as reasonably necessary for the purposes of providing the requested transportation services (such data is only used and retained to allow the service to be completed, and will be shared through a secure means);
• Ethical Introductions Limited (T/A Just Move In) 14a Commercial Road, Bournemouth, BH2 5LPfor the purpose of providing home set-up services (please see Ethical Introduction’s privacy policyhere);
• With companies who provide us with or support our IT systems and website: We use reputable third parties to provide us with our IT systems, applications and website and support for them.
• With companies who provide marketing support services to us: We use reputable third parties to provide us with marketing support services such as Awin.
• With our suppliers, to the extent necessary in order to provide services to us;
• With our payment services providers, only to the extent necessary for the purposes of processing payments, refunding payments and dealing with complaints and/or queries relating to payments and refunds;
• Whatsappas reasonably necessary to give you the option to chat with one of our support service representatives (see Whatsapp's privacy policyhere);
• LiveChat as reasonably necessary to give you the option to chat with one of our support service representatives (see LiveChat’s privacy policy here);
• Bing (see an explanation of our use of Bing in our Cookies Policy);
• Facebook (see an explanation of our use of Facebook in our Cookies Policy);
• Google Analytics and Google AdSense (see an explanation of our use of Google Analytics and Google AdSense in our Cookies Policy);
• Google Maps as reasonably necessary to assist with quoting delivery requests (see Google’s privacy policy here); and
• Trustpilot as reasonably necessary to assist with feedback requests (see Trustpilot’s privacy policy here).

We may disclose Transport Partner personal information (name, phone number, vehicle details) to you as reasonably necessary for the purposes of providing the transportation services you have requested. You are only allowed to use and retain this personal information to allow the service you have requested to complete.

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. For more information about the cookies we use, please see here

Online ads

We use online advertising to keep you aware of what we’re up to and to help you find our products. Like many companies, we may target AnyVan banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience Service.

Our use of analytics and targeted advertising tools

We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyse Google’s interest-based advertising data and/or third-party audience data (such as age, marital status, life event and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook to perform similar tasks, using your Contact, Technical, Usage and Profile Data.

To opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings or opt-out of the relevant third-party Ad Settings. For example, you can opt-out of the Google Display Advertising Features.

Overseas transfers of your personal data

We may transfer your personal data to an external third party which is based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one 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 European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

How long we keep your data

We will not keep your personal data for longer than we need to, the period for which we will keep your personal data will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain information in case of legal claim.

In some circumstances we will 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.

How we protect your data

We implement appropriate technical and organisational measures to protect data that we process from unauthorised disclosure, use, alteration, or destruction.

In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information;

1. Never share a One Time Passcode (OTP).
2. Never enter your details after clicking on a link in an email or text message.
3. Always send confidential information by encrypted email where possible this reduces the risk of interception.
4. If you’re logged into any online service do not leave your computer unattended.
5. Close your internet browser once you’ve logged off.
6. Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
7. You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.

Your rights in relation to your personal information

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• 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 your personal data. - 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 your personal data. - This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. If you want us to establish the data’s accuracy.
  2. Where our use of the data is unlawful but you do not want us to erase it.
  3. 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.
  4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data. - 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.
• Rights in relation to automated decisions. - We have some processes that may involve an automated decision however we ensure you are informed of the decision by an AnyVan staff member who will outline the validation for the decision.  You may request that we specifically do not use automated decision making however this may affect the speed at which a decision can be made.
• Right to withdraw consent. - 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.

If you wish to exercise any of the rights set out above, please contact us.

Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies as described above.

No fee usually required

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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Complaints and contact details

Complaints

If you have any complaints about the way we use your personal data please contact the data protection officer at privacy@anyvan.com who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the Information Commissioner Office (ICO). If you need more information about how to contact the ICO please let us know.

Contact details

If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by sending an email to privacy@anyvan.com or writing to the Data Protection Officer, AnyVan Limited, 5th Floor, The Triangle, 5-17 Hammersmith Grove, London, W6 0LG.

Transport Partners and Driver specifics

As a Transport Partner or a Driver, we have additional, more specific privacy details.  Please click hereto ensure you have read and understand them.

Updates to this notice

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice and you can check our website periodically to view it.

This notice was last updated July 2022

 

Transport Partners and Drivers

The following outlines the additional privacy details with regards to our Transport Partners and Drivers.  It does not replace the Privacy Policy rather it supplements it.

What additional data we collect

The additional Personal data we may collect and use about you includes;

• Identity Data includes employment references, background check results.
• Financial Data includes vehicle insurance, utility bill and credit check results.
• Technical Data includes communication content and metadata associated with the communication (generated by our App).

How we use 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 we need to perform the contractbetween AnyVan and a Transport Partner, where the Transport Partner provides you, a Driver,  with access to the App.
• 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 obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
TRANSPORT PARTNERS
To make a decision about your appointment as a Transport Partner, determine the terms on which you provide services on behalf of AnyVan and administer the contract with you as a Transport Partner.	Performance of a contract with you Necessary to comply with a legal obligation
To process payments in respect of any services you provide for AnyVan and keep a record of the same.	Performance of a contract with you Necessary to comply with a legal obligation
To provide your contact details to any Customers to enable them to contact you in order for you to provide services to them.	Performance of a contract with you Necessary for our legitimate interests (to provide the purchased service to the customer)
To review your performance as a Transport Partner, investigate any complaints concerning you, and make decisions about your continued engagement as a Transport Partner.	Performance of a contract with you Necessary for our legitimate interests (to maintain high levels of services and managing complaints)
To deal with any legal disputes that arise involving you, comply with health and safety obligations and prevent fraud.	Performance of a contract with you Necessary for our legitimate interests (to maintain high levels of services and managing complaints) To comply with our legal and regulatory obligations
DRIVERS
To administer the contract that AnyVan has entered into with a Transport Partner.	Performance of a contract
To provide your contact details to any Customers to enable them to contact you in order for you to provide services to them.	Performance of a contract with you Necessary for our legitimate interests (to provide the purchased service to the customer)
To review your performance as a Driver and investigate any complaints concerning you and any legal disputes that arise involving you.	Performance of a contract with you Necessary for our legitimate interests (to maintain high levels of services and managing complaints) To comply with our legal and regulatory obligations
To respond to, and keep a record of, any communications that you, and other users, send to us for complaint investigation and fraud prevention purposes.	Performance of a contract with you Necessary for our legitimate interests (to maintain high levels of services and managing complaints) To comply with our legal and regulatory obligations

Who we share your personal data with

In addition to the main privacy policy we routinely share personal data with:

• Customers as reasonably necessary for the purposes of
• providing the requested transportation services (such data is only used and retained to allow the service to be completed, and will be shared through a secure means) and
• providing you with a job and in allowing the Customers to contact you in relation to the job (such data is only used and retained to allow the service to be completed, and will be shared through a secure means.

All other terms and definitions from the Privacy Policy should be read in regard to your rights and protections.