Privacy Policy
DriverReviews, which is operated by Blackcircles.com Limited (Company Number SC224310) whose registered office is at Tanfield, Edinburgh, Scotland EH3 5DA “Blackcircles” ("DriverReviews"), is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it.
This policy explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.
Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.
Summary
- Who we are and how we can be contacted?
- Our websites covered by this privacy policy
- About our Privacy Manager
- Other policies and information we encourage you to read
- Information we may collect from you
- Marketing Communications
- Where we store your personal information
- Sharing your personal information
- International Transfers of Personal Data
- How long will personal information be kept by us?
- Your rights under data protection legislation
- What can you do if you’re not happy?
- About Data Security
- Changes to our Privacy Policy
1. Who we are and how we can be contacted?
Our full company name is Blackcircles.com. The website is operated by DriverReviews which is a separate division of Blackcircles.
If you need to contact us you have a number of options, you can:
- E-mail us at: enquiry@driverreviews.com
- You can send us a letter addressed to : DriverReviews Privacy Manager, Tanfield, Edinburgh, Scotland EH3 5DA
2. Our websites covered by this privacy policy
The information set out in this policy is applicable to the following website:
www.driverreviews.com
3. About our Privacy Manager
While everyone at DriverReviews is committed to protecting and respecting your privacy, we have a Privacy Manager who deals with all aspects of personal data at DriverReviews.
You can contact our Privacy Manager by sending an e-mail to enquiry@driverreviews.com.
4. Other policies and information we encourage you to read
While this Privacy Policy contains all the information you need on how we collect and use your personal information on our websites, there is information in some other places which we encourage you to read:
- Our Website Terms of Use which tells you the terms on which you may make use of our websites and should be read alongside this Privacy Policy. You can read our Website Terms of Use here(https://www.driverreviews.com/s/terms-conditions).
- Our Cookie Policy. When you use our website and other digital products and services provided by us, information can be collected through cookies to distinguish you from other users of our website and other digital products and services. We have a separate Cookie Policy which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Policy here.
- Our Review Terms and Guidelines which tells you the terms on which you provide your review to us. You can read our (https://www.driverreviews.com/s/review-terms-and-guidelines).
- Our Content Policy which tells you how what we do with the reviews that we collect (https://www.driverreviews.com/s/content-policy).
- Our Conduct Charter which explains the values which drives all DriverReviews operation, including the measures that DriverReviews adopts to ensure the authenticity of the collected reviews (https://www.driverreviews.com/s/conduct-charter).
5. Information we may collect from you
This section sets out:
- How we collect your personal information;
- Our role
- The categories of data that we collect;
- A description of how we plan to use the information we collect;
- The legal basis that we will rely on to process information collected; and
- How long we will hold the information collected.
A) Processing of personal data carried out by DriverReviews (acting as data controller) on its website
|
Data collected |
Purpose/Activity |
Lawful basis for processing |
Retention period |
|
If you request further information from us by signing up to receive any of our newsletters or marketing communications (“Marketing Data”). We may collect and process your name, surname, e-mail address. For further details, see section 6 below. |
Marketing Data is processed for the purposes of sending you the relevant notifications and/or newsletters and/or any marketing communication. |
The legal basis for this processing is consent. |
We will not keep Marketing Data more than 3 years after our last contact. |
B) Processing of personal data by DriverReviews (acting as data processor) in relation to Tyre Ratings & Reviews Collection Service
DriverReviews may process personal data in relation to Tyre Ratings and Reviews Collection Service as data processor on behalf and upon instruction of its own partners.
The Tyre Ratings & Reviews Collection Service enables the collection of customer reviews resulting from an order placed by a customer on the website of one of its partners.
Thus, when a customer places an order with one of DriverReviews’ partners, the personal data listed below will be collected.
After an order from one of the DriverReviews’ partners, DriverReviews invites the customer, by e-mail or SMS, to leave a customer review on his/her consumption experience.
The services of collection, moderation and publication of online customer reviews carried out by DriverReviews are certified by the Afnor standard (NF522 & NF ISO 20488) for the collection moderation and publication of customer reviews. , DriverReviews undertakes, as such, to comply with the Afnor standard (NF522 & NF ISO 20488) which obliges, in particular, to publish all customer reviews, positive as well as negative, subject to a moderation process defined in the Content Policy.
DriverReviews' partners, as data controllers, ensure compliance with the key principles of personal data protection, i.e. the lawfulness, fairness and transparency of the personal data collected from data subjects, which they subsequently transmit to DriverReviews.
DriverReviews' partners remain solely responsible to their customers for any failure to provide information, inaccuracy, error or omission with respect to their personal data.
The table below details the personal data processing carried out by DriverReviews (acting as data processor) under its Tyre Ratings & Reviews Collection Service on behalf of its clients (acting as data controllers):
|
Data collected |
Purpose/Activity |
Lawful basis for processing |
Retention period |
|
Information you provide to us when you complete a rating and review (“Review Data”). Information may include your full name, your e-mail address, your car registration number, order number, order date, IP address, cookies, date and time of review submission and publication, product purchased, place of purchase (in case of in-store purchase), consumer ratings, comments |
Management, publication and dissemination of customer reviews on the client's website, as well as on commercial partners’ websites and search engines. |
The legal basis for processing Review Data, we will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users. These rating and reviews on products and/or services purchased or received from DriverReviews' clients are conducted on the basis of legitimate interest to improve customer’s experience. |
While we like to retain reviews and feedback from you to help other web users, we will anonymise your reviews and feedback once the review cycle is completed, in any case not longer than 24 months after the first contact. More precisely, the DriverReviews destroy all personal data:
|
C) Processing of personal data by DriverReviews (acting as data controller) in relation to customers
DriverReviews may collect personal data from its partners’ customers for its own purpose, namely managing Reviews Display Service, which implies personal data collection until the time the tyre performance review cycle is completed.
In this context, personal data will be handled by DriverReviews for processing operations for which it determines sole the purpose and means and therefore acts as data controller.
The table below details the personal data processing carried out by DriverReviews in this context:
|
Data collected |
Purpose/Activity |
Lawful basis for processing |
Retention period |
|
Information may include your full name, your e-mail address, your car registration number, order number, order date, IP address, cookies, date and time of review submission and publication, product purchased, place of purchase (in case of in-store purchase), consumer ratings, comments |
Manage Reviews Display Service |
The legal basis for processing personal data is consumer’s consent. |
While we like to retain reviews and feedback from you to help other web users, we will anonymise your reviews and feedback once the review cycle is completed, in any case not longer than 24 months after the first contact. More precisely, the DriverReviews destroy all personal data:
|
Voluntary Information
When you provide us information (for example, the information set out in the scenarios above), in some cases we may ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them.
Statistical Information
We also collect and use aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal information but does not reveal your identity in any way. For example, we may aggregate your usage and device data to calculate the percentage of our website users accessing a specific feature of our website. Aggregated Data is used for our own business purposes only.
Sensitive Personal Information
While we do not request sensitive personal data, we do have sections on our websites where you can submit additional information, for example, when you submit a review. If you submit information on these free text section, only submit information you are comfortable providing and always bear in mind that it may be sensitive information.
6. Marketing Communications
You will receive marketing communications or newsletters from us only if you wish it.
In this context, we will use the information you provide us, usually just your name and e-mail address.
In any case, you can unsubscribe or make stop direct marketing from us at any time either
- by clicking on the unsubscribe option at the bottom of each marketing communication we send to you; and
- by contacting us by email or letter using any of the contact details set out in this notice.
7. Where we store your personal information
All information you provide to us is stored on secure servers within EEA.
While we are committed to keeping your personal information secure, the transmission of information online via the internet is not completely secure. We, together with our service providers will do our best to protect your personal information but information provided is at your sole risk.
8. Sharing your personal information
We only share your personal data with people who have a need to know such information to perform their responsibilities. We may share your personal information with the following:
Within DriverReviews - we may disclose your personal information to any member of our the DriverReviews team (we will not share it with Blackcircles other activities), to the extent necessary for the same purposes of the initial processing set out in this policy.
Service Providers - DriverReviews may share your personal information with selected service providers that DriverReviews may use to process your request or provide its services to you. These service providers act as data processors on our behalf and provide IT and system administration services, such as hosting and email services and managing the ratings and reviews.
These service providers are legally obligated to keep the personal information they may have received confidential and secure and to use your personal information the basis of our instructions only.
We may also share your personal information with third parties:
For legal reasons:
i) If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of the Blackcircles and Michelin Group, our customers, or others. In this context, we may disclose your personal information to our professional advisors who are under a duty of confidentiality.
10. International Transfers of Personal Data
DriverReviews is a business division within Blackcircles, which is a UK company belonging to an international group (Michelin Group) with databases in the various countries in which it operates. Michelin may transfer your personal data within the group to one of its databases or to its external partners located outside of your home country.
As levels of data protection vary worldwide, we do not transmit your personal data to companies located outside of the European Union unless these companies offer the same or similar level of personal data protection as Michelin.
For transfers within Michelin Group, the group has adopted internal rules governing the transfer of personal data from the European Union or European Economic Area.
Transfers of data outside the Blackcircles are governed either by the BCR of the subcontractor or by contracts containing the clauses of the European Commission for suppliers established outside the EU to guarantee a similar level of protection as that of your home country.
11. How long will personal information be kept by us?
As a rule, we will not hold your personal information for any purpose or purposes for longer than is necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For more specific retention periods, please see section 5 above.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your right to be deleted below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Your rights under data protection legislation
Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:
- The right to be informed
- The right to access your information
- The right to correct your information
- The right to delete your information
- The right to restrict processing
- The right to transfer information
- The right to object to processing
- For further information on your rights
The right to be informed
You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. We have gathered all the information you need in this privacy notice.
The right of access your information
You have the right to access the personal information we have on you. We can confirm whether or not your information is being processed and provide you with access to your personal information.
The right to correct your information
If your personal information is inaccurate or incomplete, you are entitled to have that information corrected and updated. If we have disclosed your information to any third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information we hold about you by contacting us using any of the contact methods details in this Privacy Policy.
The right to delete your information
You have the right to request the deletion or removal of your personal information where there is no reason for us to continue to process it. The circumstances in which you can request the right to be forgotten includes, where the information is no longer necessary in relation to the purpose for which it was originally collected or processed and where you have withdrawn your consent to processing.
There are some limited circumstances where the right to be forgotten does not apply – if you want to know, just ask.
The right to restrict processing
You also have the right to ‘block’ or suppress the processing of your personal information. If you request us to suppress your personal information, we will stop any further processing of it.
The right to transfer information
If you want to move or transfer your personal information to a different service provider or copy your information for your own purposes, you have the right to have your information transferred to another person.
The right to object
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.
You can also exercise the right at any time by contacting us at [enquiry@driverreviews.com]
For further information on your rights
You can find further information on your data protection rights from the Information Commissioners Office (ICO) at https://www.ico.org.uk
12. What can you do if you’re not happy?
We are committed to protecting and respecting your privacy. However, if you’re not happy with how we collect or process your information or just want some further information on your rights, you can contact us in the following ways:
- You can email us at enquiry@driverreviews.com
- You can send us a letter addressed to the DriverReviews Privacy Manager, Tanfield, Edinburgh, Scotland EH3 5DA
We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.
You can also make a complaint to ICO – further information can be found at https://ico.org.uk/make-a-complaint/
13. About Data Security
Blackcircles has implemented measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality. We use technology controls for our information systems, such as two-factor authentication (2FA), user verification, strong data encryption, and separation of roles, systems & data.
14. Changes to our Privacy Policy
We may change our policy from time to time. Any changes we make to this policy in the future will be posted on this page.
Date: [01.05.2023]