Privacy Policy

1. Introduction

This privacy policy applies between you, the user of this website and its associated services, and Elmo Drive Limited trading as elmo, who own and operate the website www.elmodrive.com. This privacy policy should be read alongside our Terms and Conditions, which can be found here.

When you interact with this website we collect some personal data from you in a number of ways. This Privacy Policy explains what data we collect, what we do with it and importantly, why we collect it.

The privacy policy only applies to Elmo Drive Limited and Users of the website www.elmodrive.com, it does not extend to other websites that can be accessed from www.elmodrive.com including any links we may provide to social media channels.

Elmo Drive Limited is the Data Controller. This means that we are responsible for overseeing the collection and processing of your personal data.

The Information Commissioner’s Office (ICO) is the body that regulates data rights in the UK. More information can be found at www.ico.org.uk. Elmo Drive Limited is registered with the ICO as a data controller under the registration number ZA568280.

elmo reserves the right to amend or modify this policy. Any material changes will be communicated to our existing customers by email.

More information about the data controller of your data:

A “data controller” is the organisation that decides on the purposes and ways that your personal data is processed (or, in other words, used). elmo’s website and services are provided by, and these decisions are made by:

Company name: Elmo Drive Limited trading as elmo

Registered address: Headway House, Crosby Way, Farnham, Surrey, England, GU9 7XG

Company number: 11860946

Email: hello@elmodrive.com

When we share personal data with third parties (see Section 4 below), they may become a data controller in respect of their own processing activities. We recommend you read their privacy notices as these will apply to their use of your personal data. We can’t take any responsibility for what’s in those notices though.

If you have any questions or queries about your data and privacy, please contact us by:

Post: Elmo Drive Limited, Headway House, Crosby Way, Farnham, Surrey, England, GU9 7XG

Email: hello@elmodrive.com

2. Legal rights and permissions

 

Your Rights

The GDPR provides the following rights for individuals:

  • The right to be informed about the collection and use of your personal data
  • The right of access to a copy of the personal data we hold about you free of charge
  • The right to rectification of any inaccurate personal data we hold about you
  • The right to erasure of the data we hold about you. This right only applies in certain circumstances.
  • The right to restrict processing (i.e. to request that we limit the processing of your data)
  • The right to data portability – to receive a copy of your data in a structured and commonly used format
  • The right to object to the processing of your personal data

You can find more information on these rights on the ICO website here. If you would like to invoke any of these rights, withdraw consent or complain, then please contact us at the address provided above or by emailing hello@elmodrive.com. Alternatively you can complain directly to the ICO by contacting them here.

Legal justification for data processing

The data collection and processing outlined in this document has been reviewed and approved by elmo, as well as external legal advisors, as necessary, appropriate, and proportionate. All the processing of your personal data is justified legally through at least one of the following means:

    • With your Consent
    • To perform a Contract
    • It is our Legal Obligation
    • It is a Vital Interest
    • It is a Public Task
    • It is in our Legitimate Interests

     

    3. The personal data we collect about you

    The types of data we process and the reasons for which we process it depends on how you’re using elmo. We are required to have a ‘lawful basis’ that we rely on to use your data in the ways we describe below, and we’ve stated what this is under each section.

    Data collected when you visit the elmo website

    Website information

    As you are reading this, then it is likely you have visited our website; www.elmodrive.com. If you are just browsing the website and have not signed up and logged into an elmo account we collect cookies and tracking information such as:

      • IP address
      • Geographic location
      • Browser type
      • Type of device used
      • Operating system

      We use this information to analyse our site performance and how people are using the website, the outputs of this allow us to make improvements. For example, if lots of people access the site using their desktop computers, we prioritise improvements to the desktop version of our website over the mobile version. This data is completely anonymised and in no way can be tracked back to you – it is used solely for our own analysis. Like most other websites we collect and use cookies. These are small files saved on your device that allow us to make our website more efficient, secure and with an improved user experience. Most of these cookies are ‘session’ cookies which means they are deleted once you leave the site, however some will remain until you delete them from your browser. For more details on this, please read our cookie policy.

      Lawful basis: your consent through our cookie banner which appears when you arrive on our website and re-asks for your consent every 3 months.

      Information from our EV Suitability Tool

      The website functionality includes an EV Suitability tool, which assesses your suitability for driving different models of electric cars based on your driving habits. To use the tool, we gather the following information:

      • Home address
      • Work address
      • Whether you have access to off-street parking
      • Your driving behaviour

      This functionality is available to all website users, but we do require your email address to provide the results. By submitting your email address, you agree to this privacy policy.

      Lawful basis: your consent.

      Data collected from elmo customers

      If you decide to create an elmo account, we will then collect additional information from you. This additional information is detailed below:

      The information you provide during the sign-up process

      • Personal information including your name and date of birth
      • Contact information including your email address, home address, and phone number

      Lawful basis: performance of a contract (namely, our Terms of Use) and our legitimate interests in creating a personalised elmo profile for you, to allow you to manage your account.

      The information you provide us during the vehicle booking process

      • Copies of documents including your, and any named drivers, driving licence(s) and DVLA Driving Record(s). In some cases, we may also ask for proof of address.
      • Payment details including your card and account details.
      • Details of your driving record including past insurance claims, motor convictions, previous accidents for you and all named drivers including in your booking.

      Lawful basis: legal obligation to comply with our fleet insurance requirements and performance of a contract (namely, our Terms of Use and General Subscription Terms).

      When you make a Subscription Order

      When you submit a Subscription Order on the website, we carry out a robust approval process. We do these checks to protect ourselves and they form part of our obligation to ensure your eligibility and suitability for our service. These checks also help prevent crime and identify fraud and money-laundering.

      We perform the following checks to verify that you are eligible to use our service:

      • Identity and document checks to verify your personal information and confirm the authenticity of your driving licence.
      • Document checks to verify your driving history. This includes confirming your licence status, entitlement, restrictions, and convictions.
      • A soft credit check on you in order to access your credit score and see any previous bankruptcies or county court judgements (CCJs). As this is a ‘soft credit check’ this will not show up on your credit history.
      • Anti-fraud checks using the electoral register, sanction lists and other available databases.

      Some of these approval checks are performed by third party sources such as suppliers chosen by elmo, anti-fraud databases, credit reference agencies, and the DVLA.

      Lawful basis: compliance with the legal obligations regarding verification of identity, eligibility and affordability for our service.

      Credit reference agencies

      As part of the Subscription Order approval, we conduct credit and identity checks by submitting your personal information to Credit Reference Agencies. These companies use public records such as the Electoral Register to verify the accuracy of the information you have provided and report to us your credit score.

      This is a soft credit check which does not show up on your credit history. This information allows us to assess your creditworthiness and determine the affordability of your subscription. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

      We use a credit reference agency called Experian for conducting a credit check. For your reference, here is a link to Experian’s Credit Reference Agency Information Notice (CRAIN): https://www.experian.co.uk/legal/crain/?utm_medium=internalRef&utm_source=Consumer Services

      You can also contact any of the CRAs currently operating in the UK to learn more (please note that the Credit Reference Agency Information Notice or ‘CRAIN’ is the same for each of the CRAs):

      During your subscription

      When you make a Subscription Order with is, we retain all data included in this order. This includes vehicle information, additional optional products added onto the subscription order, delivery dates and times, delivery details and named drivers. We will also record any insurance claims you make while in an elmo booking.

      All our vehicles are fitted with telematics. These devices which provide us with vehicle GPS tracking, usage and trip data, and risk score details. We use this data to ensure that vehicles are being used in a safe manner, we also use the data to provide information to elmo users on their driving habits. This data is linked to your account and a summary of the data we hold is shown on your ‘Driving Data’ account page. This data will be aggregated and anonymised for any analysis and your personal driving data will never be shared with a third party without your specific consent.

      Lawful basis: performance of a contract (namely, our Terms of Use and your Subscription Agreement) and our legitimate interests in delivering the expected service to you.

      Communications between you and elmo

      All communication between you and elmo – by phone, email, WhatsApp or instant messenger – are retained for a period of 5 years (or until you request we delete them). These services may be hosted by elmo’s trusted third parties.

      Lawful basis: performance of a contract (namely, our Terms of Use) and our legitimate interests in ensuring that we are able to answer or resolve any queries or complaints properly and efficiently. We also rely on our legitimate interests when recording calls and the contents of e-mails and chat sessions in order to ensure that your enquiries are properly dealt with.

      Non-anonymised web tracking

      The following information is collected when you use the elmo website while logged in:

      • Search history
      • Booking selections
      • Vehicles viewed
      • Session details including times, dates, and pages visited
      • Location and IP address

      We use this data to optimise and, in some cases, customise the website to better meet your requirements. We also use this data to understand what your preferences and provide personalised recommendations from our sales team.

      Lawful basis: our legitimate interests in maintaining and optimising our website and improving it where necessary or as identified by trends in the user data we analyse, including for security purposes and to protect your information. It’s important for us to understand how people use elmo so that we can improve and ensure our users receive a good service. You can opt out of this at any time by contacting us on hello@elmodriive.com.

      Marketing Information

      If you have opted in to receiving marketing material or signed up to our newsletter, elmo will from time to time contact you to keep you informed with company news, products or services, as well as offers or promotions which we feel may be relevant to you. This may be by telephone, post, e-mail or SMS.

      Lawful basis: your consent to receive newsletters or other offers or information from us, and our legitimate interests where we tailor those communications to suit your preferences – we do this so that we can provide you with communications and offers that are relevant to you.

      If you no longer wish to receive this marketing material just click ‘unsubscribe’ at the bottom of our emails or alternatively email us with your new marketing preferences at hello@elmodrive.com.

      “Special categories” of data

      Under data protection laws, certain “special categories” of personal data are subject to additional protections – this includes data relating to health. We don’t ask you for this data or intentionally collect it, however if you disclose to us that you have a disability (physical or mental) we might disclose this information to our third-party provider such as our delivery partner. This is to make sure we are complying with our legal and regulatory obligations and to evidence that we’ve taken appropriate steps to protect you in the case of a legal claim.

      elmo does not intend to collect or process any other special categories of personal data e.g. those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data, or data concerning anyone’s sex life or sexual orientation.

      4. Third parties we share your data with

      We sometimes uses trusted third parties to process some of your data. We share your data with the following Data Processors:

      • Our insurance partners and claim processors; to administrate your insurance policy
      • Insurance claims processors or Accident Management services; to administrate and process any insurance claims
      • Payment providers; to process payments associated with your subscription
      • Customer service providers; to organise our response to answer your questions and solve any issues you may have.
      • Fleet management providers; to administer vehicle maintenance and servicing requirements and manage vehicle logistics and deliveries.
      • The owner of the vehicles, who may need to contact you in relation to your use of the vehicle
      • Data analysis software; to perform analysis on anonymised data
      • Our Home Energy Partner; to integrate your elmo and energy accounts
      • Our Home Charge Point partner; to organise delivery of your home charge point.
      • Identity and anti-fraud services; to verify your identity and approve your account
      • Home charge point installers; to organise and manage the installation of your home charge point.
      • Anyone who contacts us on your behalf with your consent like family, friends, lawyers…
      • Marketing software; to manage our user lists, newsletters, mailing lists and promotions
      • Service providers; like Google, HubDocker and Amazon Web Services who host our databases
      • The UK Government, local councils, and regulatory bodies; to ensure we meet our regulatory and legal requirements
      • Debt-recovery companies; to help manage arrears and trace stolen vehicles. This may include vehicle repossession firms.

      Data received from third parties and how we use it

      In some instances, we may receive data about you from third parties:

      • Credit Reference Agencies – we conduct a credit check on you after you have made a booking on our website and given us permission to do so. We carry out this check through Experian. Experian provides us with a report on your credit history which we download and save to your account with us.
      • Driving licence check – we check your driving licence history through the DVLA website after you have added your DVLA check code to your account on our website. The DVLA provides us with a report on your driving history which we download and save to your account with us.

      International data sharing

      We operate within the UK. Some of our third party service providers may process personal data on our behalf in locations outside of the UK or EEA. When they do, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the UK or EEA do not have adequate data protection laws equivalent to those in the UK and EEA. If you would like more information about the safeguards we have in place, please contact us using the details in section 1.

      5. Data Retention

      As a general rule, we will retain your personal data for the time period that we need it for in order to complete the purpose that we collected it for.

      Elmo Drive Limited is authorised and regulated by the Financial Conduct Authority. This means we have an obligation to retain your data for anti-fraud and anti-money laundering purposes. For this reason, as standard protocol we will retain your data for a period of 5 years after the ends between us and yourself (unless otherwise stated or you request that we delete your personal data that we hold).

      We also have the right to anonymise your personal data for analytical purposes – this anonymised data may be retained indefinitely by us.

      6. Confidentiality and Security

      Your personal information will always be treated as private and confidential by us. We will not disclose it to anyone not specified in this policy with the following exceptions:

      • We are compelled to do so by law
      • Where there is a duty to the public to disclose
      • Where disclosure to another party is requested by you

      We have strict technical and organisational measures in place to prevent unauthorised access to or loss of your data. These include:

      • A suite of internal data protection policies and procedures which are regularly reviewed and updated
      • We adopt the principle of Privacy by Default
      • We have procedure to identify, rectify and report any breaches that do occur
      • We use encryption where suitable
      • Regular disaster recovery and penetration testing

      If you have any questions about this Privacy Policy, please contact us on hello@elmodrive.com