Privacy Policy
PRIVACY POLICY
Introduction
This Privacy Policy explains how personal data is collected and used by RCP Parking Limited (company number: 02904876), Sekura-Byk Limited (company number: 04107513), RCP Parking (Vauxhall) Ltd (company number: 11458328), RCP Brighton Ltd (company number: 09083900) and any other entities within our group or under common ownership from time to time (together referred to as “RCP”, “we”, “us”, “our” throughout this Privacy Policy).
This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.
This Privacy Policy contains the following sections:
- Important information
- Data protection principles
3. How we collect information about you
4. What information we collect and how we use it
5. Disclosures of your personal data
Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy, including “personal data” and “personal information”.
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how RCP collects and processes your personal data, including any data you may provide when you contact us via e-mail, telephone, post or through social media or any data that you provide through this website (https://rcpparking.com/) when you pay for parking, pay for a parking charge notice (“PCN”), find a car park, purchase a parking permit, submit an enquiry or join our mailing list.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
As part of our commitment to you, we have appointed a data compliance manager who is responsible for overseeing questions in relation to this Privacy Policy and RCP’s data protection compliance in general. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 9 below), please contact the data compliance manager using the following details:
E-mail address: dataprivacy@rcpparking.com
Telephone number: 01603 620720
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on 20 June 2019.
We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version. Hard copies of this Privacy Policy are available from us on request.
- Data protection principles
RCP adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:
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- Processed lawfully, fairly and in a transparent manner.
- Collected only for specified, explicit and legitimate purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
- Accurate and where necessary kept up to date.
- Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
- Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
- Not transferred to another country without appropriate safeguards being in place.
- Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.
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We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.
- How we collect information about you
We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you:
- purchase a car park ticket, permit, future booking or season pass from us;
- use one of our car parks;
- locate a car park through this website;
- pay for a PCN;
- provide information in relation to, or otherwise administer, your car park booking, permit, season pass or PCN;
- request information from us about our services;
- contact us via e-mail, telephone, post or through social media;
- take part in a customer survey;
- submit an enquiry to us; and
- join our mailing list.
Personal data is usually collected from you through direct interaction with us (either in person, by phone, by e-mail, by post, via social media or through this website). For example, you will provide your personal information when you purchase a car park ticket.
We may on occasion collect personal data from our partners or third parties, such as the DVLA, other businesses or sub-contractors that we work with and collect personal data about you, who have provided your personal information to us, either with your consent or on some other lawful basis.
We may also collect personal data when you use this website, through automated technologies, analytics providers or search engine providers. We use cookies to assist the site running as effectively as possible. For further details, please see our Cookies Policy here: https://www.rcpparking.com/cookies.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to provide our services. If so, we may have to terminate our contract with you but we will notify you if this is the case at the time.
- What information we collect and how we use it
The personal data that we collect will include:
- Contact details including your name, address, telephone number, e-mail address, account log-in details and social media details;
- Payment information, including credit/debit card details and bank account details;
- Vehicle registration number;
- Automatic Number Plate Recognition (ANPR) and CCTV images of you and your vehicle;
- Location data (see below);
- Contact history, such as any communications with us by telephone, e-mail, post, through our website or via social media;
- Transaction history, including information about previous bookings and PCNs;
- Marketing preferences; and
- Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access the website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the website to calculate the percentage of users accessing a specific feature or the number of car park users in a particular location. 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.
We will not collect or process Sensitive Personal Data (as defined in the Glossary) about you at any time.
We will only collect location data for the purposes of allowing you to identify car parks that are close to your location. You can allow or deny “Location Services” on your browser settings. If you do not allow “Location Services”, then the function enabling you to locate nearby car parks will not work. The location data is not used or retained in any manner that would allow us to track your location.
We will generally use your personal data to:
- Provide you with the information and services that you request from us;
- Process car park bookings, car park permits, season passes and future bookings;
- Process a PCN;
- Contact you by post, e-mail, telephone and via social media regarding the services and information that you have requested from us;
- Process financial transactions (including collection of payments, management of any additional charges and fees and administration of any refunds);
- Create and administer your account on our website (https://rcpparking.com/);
- Generally administer our relationship with you;
- Respond to any enquiries that you submit to us;
- Send you information by post or e-mail about new services, offers, updates and news (see the “Marketing” section below for further details);
- Comply with our legal and regulatory obligations;
- Keep a record of your relationship with us;
- Prevent and detect fraud;
- Provide customer service and support (including investigating complaints);
- Train our staff and carry out quality control;
- Review and improve our service;
- Use data analytics to improve this website, marketing, customer relationships, user experience and our organisation in general; and
- Administer and protect the website and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).
Lawful basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have ordered services from us and we need to provide them).
However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for RCP to process your information.
Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.
Marketing
We may use your contact details to send you marketing communications if you are a consumer and you have expressly given consent to receive those marking communications.
If you are not a consumer and you have requested information from us or if you have joined up to our mailing list, we may also use your contact details to send you marketing communications unless you have opted-out of receiving that marketing.
We will not share your information for marketing purposes with any company or other entity outside of RCP, unless we have your opt-in consent to do so.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time, clicking the “unsubscribe” button in the relevant e-mail or by opting-out of marketing communications in the My Account section of this website.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a booking or other contract for services that you have with us.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
- The DVLA to request details of the registered keeper of the vehicle in order to enforce non-compliance of our Parking Terms & Conditions (https://www.rcpparking.com/terms).
- Debt collection agencies, including TNC Management Ltd, for the purposes of debt recovery and administering unpaid PCNs.
- Other third parties such as POPLA, bailiffs and the Court Service in relation to the administration of unpaid PCNs and debt recovery.
- Any suppliers and sub-contractors we work with to provide you with the services that you have purchased from us.
- Service providers who provide IT, ANPR, CCTV, security, software, marketing, advertising and system administration services, including in relation to the processing of PCNs.
- Third party agencies, such as credit reference agencies.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.
- HM Revenue & Customs, law enforcement agencies, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses, carry out a restructure or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We do not and will not sell your personal data to any third party.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that 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 (such as New Zealand or Switzerland).
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has under EU data protection law.
- Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires the service provider to apply a similar standard of protection to personal data shared between the EU and the US.
Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.
How long will you use my personal data for?
Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.
LAWFUL BASIS
“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us