Privacy Notice

Introduction

Switch is dedicated to protecting its customers privacy and their personal information. This privacy statement explains the processes around what data we collect about you, how it is obtained, what it will be used for and who will access it.

Switch as a data controller is committed to ensuring that all personal information is processed in line with applicable Data Protection Laws, the information security requirements of ISO27001 and the Payment Card Industry Data Security Standards (PCI DSS) throughout the information lifecycle – collection to deletion/destruction.

This privacy statement applies to the information held about you that can be used to identify you as an individual, known as personal information. By providing personal information to Switch, you acknowledge that you understand and agree to the terms of this privacy statement and the subsequent processing of your personal information in accordance with this statement.

Providing your personal information

To enable the rental to take place Switch will assess your eligibility. In order to do so, and depending on the type of transaction, we will normally ask for the following:

- Name
- Home address
- Contact telephone number
- Email address
- Card payment details
- Date of birth
- Driving licence, and/or DVLA verification code
- ID and address confirmation documents, e.g., passport, utility, or bank statement.

Subscribing to our long-term rental service, FlexiFleet may require you to provide additional information to allow more in-depth assessment.

Providing all required information allows for your booking to be processed. Without it, Switch will not authorise the vehicle rental.

In most cases customers' personal data is collected directly from the customer, however some personal information may be provided to us by a third party or obtained from publicly available sources.

ID Verification and Soft Credit Checks

In order for Switch to verify your identity and to assess your suitability as our customer, a soft credit search may be undertaken by us or on our behalf by one of our partners.

Soft searches have no impact on your credit score or any future credit applications you might make. Those searches are not visible to companies, only you can see them on your report.

We may run more than one soft credit search during your rental if we become aware of a change in your circumstances.

The assessment of risk associated with providing you with a vehicle is Switch's legitimate business interest. Performing soft credit search helps us achieve that by detecting, managing, and preventing fraud.

Call recordings and CCTV

Switch may record phone calls in the following areas:

- Call Centre (Reservations Department),
- Customer Service Department.

The video footage showing employees, visitors and members of the public may be captured by CCTV cameras at our locations and stored on our CCTV service provider's systems.
There is no planned, regular, or scheduled sharing of CCTV footage with any external organisation. However, in the event of a security incident or suspected security incident, footage may be shared with third party organisations such as law enforcement agencies or insurance companies to assist with the detection, investigation, and prevention of crime (including fraud).

Call recordings and CCTV footage may also be used:

• to assist in quality monitoring of staff,
• to investigate and resolve a complaint.

Sensitive information

More sensitive information, known as special category data, is not routinely processed by Switch (unless it is done in relation to assessing customer's special needs). However, it may be processed passively if the ID copies, CCTV footage or call recordings reveal an individual's ethnic or racial origin, or data concerning their health (for instance, if they have a visible disability or if driving licence shows codes related to medical conditions).

Where there is a security incident captured on video footage, some criminal offence data may also be processed.

Infotainment system

Our vehicles may be equipped with an infotainment system that, if the customer chooses to use, will store certain information. If the customer connects their mobile device via Bluetooth or cable then the infotainment system can store the Bluetooth device name, contacts list, text messages, emails, call logs and any routes or destinations i.e., home/work address.

Switch does not request or require any information to be added to the infotainment by the customer. We will reset the infotainment system back to its original factory settings at the end of the hire before the vehicle's next rental.

Tracking and other data collected from the vehicle

Certain vehicles may be equipped with devices collecting in-vehicle safety and user experience data, and/or GPS trackers. Please note the devices may routinely be used only for a point in time mileage readings. Geolocation tracking will only be used if there is a reason to believe the customer has broken the terms and conditions of rental agreement, for the detection and prevention of crime, and when the vehicle needs to be retrieved.

In-vehicle safety data and user experience data may be used to support insurance claims.

Sharing information with service providers

Personal information is shared with Third Party service providers to help us fulfil contractual obligations or for Switch's legitimate purpose only. Switch may use other companies to act on our behalf, assist us in conducting our business or to perform services for us under our instruction e.g., web hosting, insurance claim management or payment processing. Any Third Party that has access to personal information will maintain appropriate security standards in line with that of Switch's to protect your personal data and use personal data we provide to them only for the purposes we specify.

Sharing information for protective or legal uses

When we are legally obliged to do so, or when it is in our legitimate interest we may share your personal information as we believe necessary and appropriate, including:

• When legally required to do so, or in response to a legal proceedings;
• For the detection or prevention of crime;
• Under applicable law, including laws outside your country of residence;
• To process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;
• To respond to requests from public and government authorities including public and government authorities outside your country of residence;
• To recover our vehicles, equipment or any monies due;
• To enforce the terms of the rental agreement contract;
• To protect our rights, privacy, safety or property, and/or that of our subsidiaries, yours or others;
• To allow us to pursue available remedies or limit the damages that we may sustain.
• With the BVRLA to add a customer to the RISC database for 'bad renters' where we have a reason to believe the customer has breached the terms of the contract, acted illegally or in any other way that would put Switch or its assets at risk.

Use of cookies

Cookies are small text files placed or sent to your computer by a website which collect certain information about you to provide you with a better online experience. In addition, cookies are used to measure usage of various pages on our website to help us make our information more pertinent to your needs and easy for you to access.

To learn more about cookies and how to manage them please visit www.aboutcookies.org or Cookies | ICO

Our website may contain links to third party web sites. We do not monitor or control the information collected when you choose to "click through" links to access these websites.

Marketing preferences

We may use a Third-Party mailing company to email customers with special offers, events and news relating to Switch. We will only provide them with your email address which will never be passed on to any other company, and you will only receive information relating to Switch's products or services. To receive this communication, you will need to opt in when submitting your booking request on our website. If you have an account with us, you can manage this preference by logging in and clicking on the 'My Account' link at the top of the page. You can unsubscribe at any time by clicking on the 'unsubscribe' link at the bottom of any of our marketing emails.

How your information is stored

Your personal information will be stored in line with Switch's Information Security and Records Retention policies. In most cases your data we will only be kept for as long as we have a legal obligation to store it. In some cases, we may choose to keep it for longer (e.g. insurance claims data).

The token allocated to your payment card will be stored for up to 12 months and may be used post rental to cover the cost of missing fuel, damage, or fines incurred during your hire.

Your information - Your choice

Please contact us directly if you wish to:

• Confirm if, how and why your data is being processed;
• Request copies of the information held about you by Switch, known as Subject Access Request;
• Rectify any inaccurate or incomplete data;
• Delete or remove any personal data where there is no compelling reason for its continued processing;
• Restrict the processing of your personal data;
• Complain about the way your data is being processed by Switch;
• Report a data breach;

Email: datagovernance@scotgroup.com

Post: FAO Data Governance, Switch, Scot House, Matford Park Road, Exeter, EX2 8AW.

We have strict procedures for disclosure of personal information to prevent any unauthorised access and may ask you to prove your identity before we disclose any information to you.

Complaints

If you have any concerns regarding processing of your data by Switch, please email datagovernance@scotgroup.com so that we can address any issues.

You may also choose to direct any information processing complaints to the Information Commissioner's Office. Information on how to do this is available at www.ico.org.uk/complaints or telephone helpline 0303 123 1113.

Switch is registered with the ICO – reference Z945438X

In summary

This privacy statement will be maintained and updated to reflect any changes in Switch's processes or any changes to applicable data protection laws that might impact how we manage your personal information. We encourage all users to regularly review this statement to ensure they are always fully aware of how Switch manages and protects their personal information.

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