Privacy Policy
www.onroute.io (our website) is provided by Onroute.io Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA). In addition, we comply with applicable privacy laws in the United States and Canada, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act, (as amended) (CPRA), and the Personal Information Protection and Electronic Documents Act (PIPEDA).
Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
If you are a resident of California or Canada, additional terms may apply. Please refer to the section “Additional Rights for US and Canadian Residents” below.
This privacy policy is divided into the following sections:
- What this policy applies to
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK and EEA
- Cookies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number and company details
- location data, if you choose to give this to us
- details of any information, feedback or other matters you give to us by phone, email, post or via social media
- information about how you use our website and technology systems
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of the website.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you contact us via the website; and
- indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explained in the section on ‘Cookies’ below
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Creating and managing your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
| Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations |
| Enforcing legal rights or defend or undertake legal proceedings | Depending on the circumstances: |
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances: — your consent as gathered by the cookies tool on our website—see ‘Cookies’ below — where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time. (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
|
Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests, ie to promote our business to existing and
former customers |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency | Depending on the circumstances: |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR and EU GDPR | Relevant categories of personal data |
|---|---|---|---|
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Addressing and sending communications to you as required by data
protection laws, ie: | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | — your name, address and contact information, including email address
and telephone number and company details
|
| Addressing and sending communications to you as required by law | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | — your name, address and contact information, including email address and telephone number and company details | |
Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | — your name, address and contact information, including email address and telephone number and company details |
How and why we use your personal data—Special category personal data
We do not collect special category personal data.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at dpo@onroute.io or
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- other third parties we use to help us run our business, eg website hosts and website analytics providers
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
-
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
-
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
-
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available on request.
Transferring your personal data out of the UK and EEA
We do not transfer your personal data out of the UK or EEA.
Cookies
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies, web beacons, action tags, single-pixel gifs on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies, web beacons, action tags, single-pixel gifs, and our use of ‘cookies’, please see our Cookie Policy.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use | The right to object: — at any time to your personal data being used for direct marketing (including profiling) — in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us by email at dpo@onroute.io. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself by giving your name, contact details and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Additional Rights for US and Canadian Residents
Californian residents
This section outlines specific rights granted under the CCPA to individual California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This section is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their Personal Data that is not set forth in this section is otherwise set forth in this Privacy Policy. For the avoidance of doubt, for purposes of this Privacy Policy, references to Personal Data in the Section (“Your Rights”) of this Privacy Policy and in sections that are specific to rights under the GDPR are deemed to include references to “personal information” as defined under the CCPA.
Deletion Rights: You have the right to request that we delete any of your Personal Data that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing and provide an explanation if we cannot comply with a specific request.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of Personal Data specific to you over the last twelve (12) months. Such information includes:
- the categories of Personal Data we collected about you;
- the categories of sources from which the Personal Data was collected;
- our business or commercial purpose for collecting such Personal Data;
- the categories of third parties with whom we share the Personal Data;
- the specific pieces of Personal Data we collected about you; and
- whether we disclosed your Personal Data to a third party, and, if yes, the categories of Personal Data that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA or to access this notice in an alternative format, please submit a request on your behalf using any of the methods in the ‘How to contact us’ section below.
For Canadian residents
If you are a Canadian resident, you have the right to:
- Access the personal information we hold about you.
- Request correction of inaccurate or incomplete personal information.
- Withdraw consent for the collection, use or disclosure of your personal information, subject to legal or contractual restrictions.
To exercise any of these rights, or to make an inquiry or complaint about how we handle your personal information, please contact us using the details below.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and are undergoing the process to become ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
Onroute.io Limited
One Canada Square, London, E14 5AA
dpo@onroute.io
0330 043 9859
Individuals in the EEA
We have appointed Neil Simpson to be our data protection representative within the EEA. Individuals within the EEA can contact us direct (see above).