MATCHMYROUTE PRIVACY AND COOKIE POLICY

MatchMyRoute Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our app and website, www.matchmyroute.co.uk ("Our Website and Our App") and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read the Privacy Policy carefully and ensure that you understand it. This policy applies to users of MatchMyRoute’s services, including users of MatchMyRoute’s apps, websites or other services.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

"Account": means an account required to access and/or use certain areas and features of Our App and Website;

"Cookie": means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are set out in Part 14, below; and

"Cookie Law": means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

"We/Us/Our": means MatchMyRoute Limited, a limited company registered in England under company number 10945024, with its registered address at 86-90 Paul Street, London, England, EC2A 4NE;

"Marketplace": means any goods or services purchased from a Merchant via the MatchMyRoute app or website;

"Merchant": means the independent third parties who provide the relevant All Services to Users;

"User": means a user of Our App or Website;

"Order": means any order placed through Our platform to be fulfilled by a Merchant via the Marketplace;

"All Services/Services": means the facilitating of User interactions with Third Party Providers or other Users to facilitate the Services;

"Third Party Payment Processor": means the external party processing User and Merchant payments on the behalf of MatchMyRoute;

"Third Party App Monitoring and Error Tracking": means the external party providing application monitoring and error tracking services.

2. Information About Us

Our App and Website are owned and operated by MatchMyRoute Limited, a limited company registered in England under company number 10945024.

Registered address: 86-90 Paul Street, London, England, EC2A 4NE.

Data Protection Officer: David Kerr.

Email address: hello@matchmyroute.co.uk.

Telephone number: +44 7825870089.

Postal address: 86-90 Paul Street, London, England, EC2A 4NE.

3. What Does This Policy Cover?

This Privacy Policy applies to the use of Our Website and Our App. Both may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") and the Data Protection Act 2018 (collectively, "the Data Protection Legislation") as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a)     The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b)     The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c)     The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d)     The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

e)     The right to restrict (i.e. prevent) the processing of your personal data.

f)     The right to object to us using your personal data for a particular purpose or purposes.

g)     The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h)     The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us in first instance, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Website, we may collect and hold some or all of the personal non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies.

To give you a customised experience, improve our services and to deliver the Services the following data in relation to Our App and Website is collected.

Data CollectedHow We Collect the Data
Identity information including first name, last name, profile photograph and gender.User provides it to us during the account registration process.
Contact information including email.User provides it to us during the account registration process.
Vehicle information including vehicle registration number, number of seats, vehicle manufacturer and vehicle model.User provides it to us before they publish and index their journeys on our website.
Location information including data such as GPS and IP address.User provides the location information when using Our App and Website.
Profile information including account password.User provides it to us during the account registration process.
Data from third parties as such Facebook including first name, last name, and email.Third parties provide it to us when a User logs into their account via third party authentication.
Journey information including the departure postal address, destination postal address, date and time of journeys a User has created, requested or accepted.User provides it when publishing and indexing their journeys on our website, and when user requests to share a journey with other users.
Precise and coarse location information.Sent from the App after a User interaction with one of Our Services.
The Users identifying information including screen name, account ID, assigned user ID, customer number, the device’s advertising identifier, or device ID.Sent from the App after a User interaction with one of Our Services.
Payment transaction ID from Stripe.Stripe provides us with the payment ID once a user payment is complete.
First and last names, email address, phone number, physical address.Users provide them when creating shops, products and Orders.
Crash and performance data.App sends crash reports to the Third Party App Monitoring and Error Tracking when an error occurs.

Users may at any time restrict what data they allow Our App to collect, but MatchMyRoute will be limited in what Services can be provided in those cases and the app may not work fully.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We DoWhat Data We UseOur Lawful Basis
Register you on Our Website.Identity dataNecessary for our legitimate interests. Necessary for providing our services to you - allows us to uniquely identify you and link you with journeys that you have created or requested to share so that, for example, if a User requests a journey you have created, we are able to notify you and if a User accepts a journey you have requested to share we are a able to notify you.
Provide and manage your Account.Identity dataNecessary for our legitimate interests. Necessary for providing our services to you - allows us to uniquely identify you and link you with journeys that you have created or requested to share so that, for example, if a User requests a journey you have created, we are able to notify you and if a User accepts a journey you have requested to share we are a able to notify you.
Provide and manage your access to Our Website.Identity dataNecessary for our legitimate interests. Necessary for providing our services to you.
Personalise and tailor your experience on Our Website.Identity dataNecessary for our legitimate interests - allows us to enhance your experience on Our Website by displaying content we believe would be of interest to you.
Supply our products and/or services to you.Identity data
Location data
Vehicle data
Necessary for our legitimate interests. Necessary for providing our services to you.
Communicate with you.Identity dataNecessary for our legitimate interests. Necessary for providing our services to you - enables Us to verify your email address when you register with us, and notify you of matters relating to Our App, Our Website and Our Shared Journey Services.
Supply you with information by email that you have opted-in-to (you may opt-out at any time).Identity data
Location data
Vehicle data
Necessary for our legitimate interests - enables us to share information with you that we believe would be of interest to you.

Please see our Cookie Policy for further information.
Manage our relationship with you which will include notifying you about changes to our terms or privacy policy.Identity dataNecessary to comply with legal obligations.
Provide EV charging locations, displaying Merchant distance from the User, showing location based Merchant results and showing the User current location when creating a journey.Precise and coarse location information.Necessary for our legitimate interests. Present user location information is required to provide accurate location based services.
Authenticate the User with our App.Users identifying information including screen name, account ID and user ID.Necessary for our legitimate interests. This data allows Us to protect user accounts and process payments correctly.
Cross reference the transaction ID with Orders on our platform to prove that they have been paid.Payment transaction ID from Stripe.Necessary for our legitimate interests. The transaction ID allows us to identify the payment status.
MatchMyRoute and Merchants operating on the Marketplace may contact you regarding the Services We offer.First and last names, email address, phone number, physical address.Necessary for our legitimate interests. This data allows Merchants to inform the User of changes that need to be made to the Order or to clarify Order details. Addresses are used by the User to locate the shop when arranging collection.
Correct system errors.Crash and performance data.Necessary for our legitimate interests. Crash reports allow us to fix errors in a timely manner.
Create visual associations for Users.User-supplied images.Necessary for our legitimate interests. The profile photograph provides Users with a visual identity digitally.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including Facebook, Google Analytics, Cloudflare) whose content appears on Our Website may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of DataHow Long We Keep It
Identity and contact dataAs long as the account is active.
Vehicle dataAs long as the account is active.
Location / journey dataAs long as the account is active.
Diagnostic DataAs long as the account is active.

9. How and Where Do You Store or Transfer My Personal Data?

We will store or transfer your personal data within the European Economic Area (the "EEA"). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the "EEA" consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as "third countries" and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

1. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

2. procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

3. encrypting your account password.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply certain products and/or services.

When you register your account with us, we share your email with our email service provider. We need to handle your personal information in this way to provide the services to you. This may include sending you notices about the changes of our product, your account confirmation and the changes to our terms or privacy policy.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

To facilitate payment processing postal address, username and email address is shared with our Third Party Payment Processor. This data is shared to allow us to connect transactions with Orders in Our App, this is required as we don't hold your financial information beyond the transaction id. Further information can be found Third Party Payment Processor Data Collection Terms.

In some limited circumstances, Our App may crash and send diagnostic data to Us via our Third Party App Monitoring and Error Tracking services. Crash and performance data is used to improve the platform and allow us to correct issues Users may encounter. This data may contain User identifying information but only contains what is strictly necessary. It is subject to the data retention policy outlined in sub-Clause 8 "Diagnostic Data".

11. How Can I Control My Personal Data?

1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails at the point of providing your details and by managing your Account).

2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service ("the TPS"), the Corporate Telephone Preference Service ("the CTPS"), and the Mailing Preference Service ("the MPS"). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. How Can I Control My Personal Data?

You may access certain areas of Our Website without providing any personal data at all. However, to use all features and functions available on Our Website you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Website may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Website and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Website to enhance performance. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Website and your use and experience of Our Website will not be impaired by refusing consent to them.

All Cookies used by and on Our Website are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt that will appear at the bottom of the screen requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide our service to you. Our Website depends on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Name of CookiePurposeStrictly Necessary
csrftokenSecurity cookie to protect against cross-site request forgeryYes
sessionidSecurity cookie to identify your authentication information.Yes

and the following third-party Cookies may be placed on your computer or device:

Name of CookiePurposePurpose
__cfduidCloudFlareIt is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.
__cf_bmCloudFlareIt is a functional cookie necessary to support Cloudflare Bot Management, currently in private beta
_biz_flagsACloudFlareIt is used to support performance optimisation and security.
_biz_nACloudFlareIt is used to support performance optimisation and security.
_biz_pendingACloudFlareIt is used to support performance optimisation and security.
_biz_sidCloudFlareIt is used to support performance optimisation and security of the website and your access to it.
_biz_uidCloudFlareIt is used to support performance optimisation and security of the website and your access to it.

Our Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Website is used. This, in turn, enables us to improve Our Website and the products and/or services offered through it.

The analytics services used by Our Website uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Website, it does enable us to continually improve Our Website, making it a better and more useful experience for you.

The analytics services used by Our Website uses the following Cookies:

Name of CookieFirst / Third PartyProviderPurpose
_gaThirdGoogle analyticsUsed to distinguish users
_gidThirdGoogle analyticsUsed to distinguish users
_gatThirdGoogle analyticsUsed to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm.
AMP_TOKENThirdGoogle analyticsContains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, in-flight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<property-id>ThirdGoogle analyticsContains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
consentThirdGoogle analyticsThis cookie is used by Google Analytics to analyse how visitors find our website, how often they visit it, and which pages are the most popular.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Website more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of David Kerr):

Email address: hello@matchmyroute.co.uk

Telephone number: +44 7825870089.

Postal Address: 86-90 Paul Street, London, England, EC2A 4NE.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Website following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 1 Aug 2019.