11633184, registered office 28 Leskinnick Terrace, Penzance, TR18 2HB trading as The Pasty
your legal rights and obligations so please read it carefully. It applies to personal data you provide
to us whether you are a Driver, Passenger or other user of our mobile app If you do not agree to be
If you have any questions, you can contact us at firstname.lastname@example.org
we do so, and the changes substantially affect your rights or obligations, we shall notify you if we
have your email address. Otherwise, you are responsible for regularly reviewing this Privacy & Cookie
Policy so that you are aware of any changes to it.
1.3 We are the controller of your personal data for the purposes of applicable data protection
legislation. By personal data we mean identifiable information about you, such as your name, email
address, gender, mobile and home telephone number and your IP address.
2. Collecting Your Data
2.1 If you wish to register on The Pasty Connection as a Driver or Passenger you must provide us with:
a photograph of yourself, your name, telephone number and email address. You cannot create an
account on The Pasty Connection unless you provide this information to us.
profile on The Pasty Connection, you may provide additional personal data to us and we shall process
2.5 All personal data that you provide to us must be true, complete and accurate, and you must notify
us of any changes to such personal data. If you provide us with inaccurate or false data, and we
suspect or identify fraud, we will record this. You must not register under someone else’s name.
2.6 When you contact us by email or post, we may keep a record of the correspondence and we may also
record any telephone call we have with you.
2.7 We may also receive personal data about you from other users of The Pasty Connection. In
particular, Drivers may share with us information about Passengers, and likewise, Passengers may share
with us information about Drivers.
2.8 We may also receive personal data about you from third parties, such as from payment providers,
insurers and the DVLA
3. Data we automatically collect
3.1 When you use our app, we, or third parties on our behalf, automatically collect and store
information about your device and your activities. This information could include (a) your device’s
unique ID number; (b) technical information about your device such as type of device, web browser or
operating system; (c) your preferences and settings such as time zone and language; and (d) statistical
data about your browsing actions and patterns. We collect this information using cookies in accordance
anonymous basis to improve our app, and for analytical and research purposes.
3.2 We will also collect details about your location on the day that you agree to share a lift on The
Pasty Connection provided you agree. We collect this information using cookies in accordance with the
Driver/Passenger that you have agreed to share the lift.
4. Lawful Use of your personal data
4.1 We will only use your personal data where we have a lawful basis to do so. The lawful purposes that
contract with you; compliance with legal requirements; and legitimate interests. When we refer to
legitimate interests we mean our legitimate business interests in the normal running of our business
which do not materially impact your rights, freedom or interests.
4.2 The main reason that we use your personal data is to allow you to use The Pasty Connection platform
Connection, we may share your data with any organisation that we need to do so in order to verify your
identity; for example, we may share vehicle registration plate details with third parties to enure that
the vehicle is insured and has a valid MOT certification in place.
4.2 We may also use your personal data for our legitimate interests, including dealing with any
example anti-money laundering and fraud prevention purposes), for audit purposes and to contact you
4.3 You understand that your personal data may be visible to or shared with any user of The Pasty
Connection in accordance with our Terms of
5. Who do we share your data with?
5.1 For our legitimate interests, we may share your personal data with any service providers,
sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance
with our instructions, including payment providers, IT service providers, accountants, auditors and
lawyers. We shall provide our service providers, sub-contractors and agents only with such of your
personal data as they need to provide the service for us and if we stop using their services, we shall
request that they delete your personal data or make it anonymous within their systems.
5.2 In order to comply with our legal obligations, under certain circumstances we may have to disclose
your personal data under applicable laws and/or regulations or in response to a court order including
to protect a third party’s rights, property, or safety.
5.3 For our legitimate interests, we may also share your personal data in connection with, or during
negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition
of all or a portion of our business by or into another company.
6.1 When you register with us, you will be offered the opportunity to consent to receive news and
promotional offers from us. We record your consent. You can choose to no longer receive marketing
emails from us by contacting us at email@example.com or by clicking unsubscribe from a marketing email. If you do
unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to
6.2 We shall therefore retain your personal data in our records for marketing purposes until you notify
us that you no longer wish to receive marketing emails from us.
7. Where we hold and process your personal data
7.1 Some or all of your personal data may be stored or transferred outside of the European Economic
Area (the EEA) for any reason, including for example, if our email server is located in a country
outside the EEA or if any of our service providers are based outside of the EEA
7.2 Where your personal data is transferred outside the EEA, it will only be transferred to countries
that have been identified as providing adequate protection for personal data (like New Zealand), or to
a third party where we have approved transfer mechanisms in place to protect your personal data – i.e.,
by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity
is Privacy Shield certified (for transfers to US-based third parties).
8. Cookies and Device IDs
8.1 A cookie is a small text file containing a unique identification number that is transferred
(through your browser) from our app to your device. The cookie identifies your browser but will not let
us know any personal data about you, such as your name and/or address. These files are then used by our
app to identify when users return.
8.2 Most browsers are initially set up to accept cookies. You can change your browser settings either
to notify you when you have received a cookie, or to refuse to accept cookies. Please note that our app
may not operate efficiently if you refuse to accept cookies.
8.3 We use and store your mobile device IDs, which is the unique identifier assigned to a device by the
manufacturer, to recognise you. Device IDs cannot be deleted.
8.4 We also use third party cookies such Google Analytics to monitor how our app is used. These cookies
collect information anonymously and generate reports detailing information such as the number of visits
to the system, where visitors generally came from, how long they stayed on the system, and which pages
they visited. They place several persistent cookies on your device. These do not collect any personal
data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent
these third party cookies from logging your visits.
8.5 We also use social media buttons and/or plugins on the app that allow you to connect with your
social network in various ways. For these to work the relevant social media sites (Twitter, Facebook
and Google +) will set cookies which may be used to enhance your profile on their site or contribute to
the data they hold for various purposes outlined in their respective privacy policies.
9.1 We shall process your personal data in a manner that ensures appropriate security of the personal
data, including protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures. All information you
provide to us is stored on our secure servers.
9.2 Where we have given, or you have chosen a password, you are responsible for keeping this password
9.3 However, you acknowledge that no system can be completely secure. Therefore, although we take these
steps to secure your personal data, we do not promise that your personal data will always remain
10. Your rights
10.1 You have a number of rights under applicable data protection legislation.
Right of access: You have the right to obtain from us a copy of the personal data that we hold
Right to rectification: You can require us to correct errors in the personal data that we
process for you if it is inaccurate, incomplete or out of date.
Right to portability: You can request that we transfer your personal data to another provider.
Right to restriction of processing: In certain circumstances, you have the right to require
that we restrict the processing of your personal information.
Right to be forgotten: You also have the right at any time to require that we delete the
personal data that we hold for you, where it is no longer necessary for us to hold it. However,
whilst we respect your right to be forgotten, we may still retain your personal data in
accordance with applicable laws.
Right to stop receiving marketing information: You can ask us to stop sending you information
about our services, but please note we shall continue to contact you in relation to any matters
relating to your The Pasty Connection account.
10.2 Please note, we reserve the right to charge an administrative fee if your request in relation to
your rights is manifestly unfounded or excessive.
10.3 If you have any complaints in relation to this Privacy & Cookies Policy or otherwise in relation
to our processing of your personal data, please tell us. We shall review and investigate your complaint
and try to get back to you within a reasonable time. You can also contact the Information Commissioner,
see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local
11. Retention of personal data
11.1 We retain your personal data in accordance with applicable laws. Therefore, if you register with
us, we shall retain your personal data until you close your The Pasty Connection account except where
we are required to retain your personal data for longer to comply with accounting and taxation
requirements. If you receive marketing communications from us, we shall retain your personal data until
you opt out of receiving such communications.
11.2 If you have otherwise contacted us with a question or comment, we shall retain your personal data
for 6 months following such contact to respond to any further queries you might have.
be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect
the intentions of the parties and all other provisions shall remain in full force and effect.
England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.