1. WHAT THIS PRIVACY NOTICE COVERS
This Privacy Notice provides information regarding the processing of your personal data when using services and/or purchasing products from or on behalf of the Prax Group whether as:
- a retail customer
- a member of the Prax Group loyalty program
- a visitor to any of the Prax Group’s websites
- a user of the Prax Group’s applications
This Privacy Notice explains what personal data we process about you; why we are processing your personal data and for which purposes; for how long we hold your personal data for; and how to access and update your personal data.
2. PERSONAL DATA WE PROCESS ABOUT YOU
This Privacy Notice explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as your rights and the options you have regarding your personal data and where to go for further information. This is in accordance with the Data Protection Act 2018, the UK adoption of General Data Protection Regulation (GDPR) and other applicable data protection regulation.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information.
We may collect and process the following information about you, including:
- Information that you provide to us – your name, e-mail address and gender, your contact preferences and information necessary for answering any security questions. If you decide to become a member of the Prax Group Loyalty Programme, we may ask you to provide further personal data necessary for the performance of such services and/or authentication, such as type of vehicle, driver pattern, date of birth (if collected), communications preferences and mobile number;
- Information that we obtain through your use of the Prax Group services – we will also collect information about how and where you use or purchase the Prax Group services and products. Such information may include electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable cookies and similar technologies. Your purchase history includes data regarding: a) specific products you buy, (b) the total amount of your purchases per transaction, (c) the time and place of the purchases you make, and (d) the payment method you use, including payment methods embedded in the Prax Group Apps (such as mobile payment option);
- If you are a member of the Prax Group Loyalty Programme – we will collect information about your participation in these; this includes data regarding: (a) the type and description of the award you have chosen, (b) the amount of points you have redeemed, (c) the frequency and time of redemption of your points, and (d) the delivery method used to provide you with your award (if any). We may also collect your recorded journeys, including your vehicle co-ordinates, speed and acceleration, comparing this against other users (if you have consented to the collection of such information, including your location);
- Information gathered through social media pages – we may collect your user name, profile picture, hometown, e-mail address and gender.
3. DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up-to-date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
4. WHY WE PROCESS YOUR PERSONAL DATA
We process your personal data a) in order to satisfy our obligations to comply with laws and regulations; b) for legitimate business interest, and c) where we have your explicit consent.
Where the processing is based on consent, you have the right to withdraw your consent at any time.
5. HOW WE USE INFORMATION ABOUT YOU
We process your personal data for the following purposes:
- customer service and development of our products and services;
- managing relationships and marketing;
- providing our products and services to you;
- market surveys and marketing strategies;
- account management;
- promotions and contests;
- detecting or preventing fraud;
- storing, deleting or anonymising your personal data;
- audits, investigations, dispute resolution or insurance purposes, litigation or defence of claims;
- research;
- legal and/or regulatory compliance.
6. DATA SHARING
We process your data for the purposes referred above and will only be shared on a strict need-to-know basis with:
- Other companies within the Prax Group of companies;
- Authorised third party agents, service providers, external auditors and/or subcontractors of the Prax Group; or
- A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Prax Group company/companies is subject to or as permitted by applicable local law.
We will only disclose your personal data to other organisations where it is necessary (i) to enable the organisation to provide services for or on behalf of us, (ii) to comply with applicable legal requirements, (iii) to protect or defend our rights or property, or (iv) to protect the health, safety and well-being of our employees, contractors, visitors or members of the public.
7. TRANSFER TO OTHER COUNTRIES
Where your personal data has been transferred to companies within the Prax Group and/or authorised third parties located outside of your country, we take organisational, contractual, and legal measures to ensure that your personal data is processed for the purposes mentioned above and that adequate levels of protection are in place to safeguard personal data. These measures may include data sharing/data transfer agreements for transfers within the Prax Group, and EU-approved transferred mechanisms for transfers to third parties.
8. SECURITY OF PERSONAL DATA
The Prax Group is committed to safeguarding your personal data. We have implemented physical security, cybersecurity technology and policies with the objective of protecting your privacy from unauthorised access, improper use, alteration or disclosure. We update and review these measures on an ongoing basis.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
9. HOW LONG WE KEEP PERSONAL DATA FOR
All information, including personal data, is securely deleted once no longer required for the legitimate business purpose or for legal or the regulatory purpose for which it was collected. In all cases, information may be held for a longer period where there is legal or regulatory reason to do so. In some circumstances, we may anonymise your personal information so that it can nolonger be associated with you; in which case, we may use such information without further notice to you.
10. SOCIAL MEDIA
If you choose to interact with Prax through social media on a Prax administered social media page such as X (formerly Twitter), Facebook, LinkedIn or YouTube, your personal data (such as your name, your profile picture and the fact that you are interested in the Prax Group) will be visible to all visitors, depending on your privacy settings on the relevant social media platform, and will also be visible to Prax. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. Prax does not track your activity across the different social media sites that you use. If you send a message to Prax via any messenger service on a social media platform, please note these messages will be held on file and shared internally by Prax via e-mail to ensure swift resolution. These messages will be retained as long as is necessary and in line with the Prax Data Retention Policy.
Additionally, and to the extent the Prax Group is jointly responsible with a social media platform of a Prax social media page, Prax will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Prax social media pages. For more information on how your personal data is processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
11. YOUR RIGHTS IN RELATION TO PERSONAL DATA
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- access to your personal data;
- correction or deletion of the personal data (but only where it is no longer required for a legitimate business purpose);
- that you no longer receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner;
- object to the processing of your personal data;
- that the processing of your personal data is restricted;
- that you receive personal data that you have provided to the Prax Group, in a structured, digital form to be transmitted to another party, if this is technically feasible;
- withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. To withdraw your consent, pleasecontact us using the contact details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
12. ENQUIRIES, CONCERNS OR COMPLAINTS
If you have any queries or complaints regarding your personal data, please contact: privacy@prax.com.
You can also contact the Data Privacy Officer (DPO) at: The Prax Group York House, 45 Seymour Street, London W1H 7JT, United Kingdom.
If you are not satisfied with our handling of personal data, you have the right to submit a complaint to your local data protection authority or the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
13. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is subject to change over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in October 2024.
