1. Introduction

This policy applies when you:

• Visit or use our websites;
• Purchase or enquire about our products;
• Create an account;
• Register a product or warranty;
• Purchase or use a subscription;
• Use a Road Angel mobile application;
• Install, activate or use a Road Angel tracker;
• Use a connected dash cam or other connected product;
• Contact our customer service, technical support, sales or monitoring teams;
• Enter a competition, survey or promotion;
• Become an installer, dealer, supplier or business partner; or
• Otherwise interact with Road Angel Group.

We process personal information in accordance with applicable data-protection and privacy legislation, including the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations.

2. Who Is Responsible for Your Information?

Depending on the product or service involved, the data controller responsible for your personal information will be:

Where appropriate, these companies may act as joint controllers or separate controllers for particular products, services or activities.

3. Personal Information We Collect

3.1 Identity and contact information

• Full name and title;
• Postal, billing and delivery addresses;
• Email address and telephone numbers;
• Alternative or emergency contact details;
• Account username and customer reference number;
• Electronic or typed signatures; and
• Information used to verify your identity.

3.2 Order, payment and transaction information

• Products and services purchased;
• Order and transaction history;
• Subscription details and billing frequency;
• Payment status, refunds and cancellations;
• Delivery and installation information;
• Invoices, credit notes and warranty information; and
• Limited payment information.

Payment-card details are normally processed directly by authorised payment providers. We do not ordinarily retain complete payment-card numbers.

3.3 Account and subscription information

• Account login and protected password information;
• Subscription type, start date and renewal date;
• Device entitlements and connected products;
• Activation status and account preferences;
• Marketing preferences; and
• Customer-service history.

3.4 Vehicle information

• Vehicle registration number;
• Vehicle identification number or chassis number;
• Make, model, colour and year;
• Fuel or engine type and mileage;
• Vehicle condition and distinguishing features;
• Installation location within the vehicle;
• Vehicle ownership or keeper information where required;
• Vehicle insurance information where necessary; and
• Vehicle fault or diagnostic information.

3.5 Product and device information

• Product type and model;
• Serial number, device identifier and IMEI;
• SIM telephone number and SIM identifier;
• Firmware and software versions;
• Activation and installation dates;
• Installer information;
• Device status, battery, power and connectivity information;
• Diagnostic and technical logs;
• Crash, error and event reports;
• Product configuration; and
• Information about how a product or application is used.

3.6 Tracker installation and onboarding information

Where you register, install, activate or use a Road Angel vehicle tracker or monitoring service, we may collect:

• Your name, address and contact details;
• Alternative or emergency contact details;
• Vehicle and tracker information;
• Installation and installer records;
• Vehicle condition and distinguishing features;
• Typed or electronic signatures;
• Customer confirmations;
• Account activation and subscription information;
• Security-verification information; and
• Communications relating to installation, activation, monitoring, servicing, theft or recovery.

3.7 Location, journey and movement information

• GPS position and current or historic location;
• Journey start and end information;
• Journey history and routes;
• Speed and direction of travel;
• Ignition, power and disconnection events;
• Tow-away, tamper and impact events;
• Geofence and unauthorised movement alerts;
• Theft alerts;
• Driver-recognition information;
• Date and time information; and
• Recovery activity.

3.8 Dash-cam, video, audio and image information

• Road-facing, rear-facing and cabin-facing video;
• Still images and audio;
• GPS, speed, date and time information;
• Impact, emergency and triggered recordings;
• Parking-mode recordings;
• Number-plate images;
• Cloud-uploaded footage; and
• User-selected or user-uploaded footage.

3.9 Application and mobile-device information

• Mobile-device model and operating system;
• App version and IP address;
• Device identifiers;
• Bluetooth, Wi-Fi and mobile-network information;
• App usage and permissions;
• Location, camera, microphone and storage access;
• Notification settings; and
• Crash and diagnostic information.

3.10 Website and online information

• IP address, browser and device type;
• Operating system and approximate location;
• Pages and products viewed;
• Time spent, links clicked and referring website;
• Basket, checkout and account activity;
• Search activity;
• Cookie and advertising identifiers; and
• Analytics information.

3.11 Communications and call recordings

• Emails, letters, webchat and SMS messages;
• WhatsApp and social-media communications;
• Support tickets and complaint records;
• Staff notes;
• Telephone number, call date, time and duration; and
• Telephone call recordings.

3.12 Marketing and preferences

• Marketing consent and communication preferences;
• Email, SMS and advertising engagement;
• Product interests;
• Promotion and competition history;
• Survey responses; and
• Unsubscribe or objection requests.

3.13 Installer, dealer and business-contact information

• Name, job title and employer;
• Business address, phone number and email address;
• Account and contract information;
• Installation activity;
• Training and certification records;
• Sales and commission information;
• Payment information; and
• Support and communication records.

4. Information Received From Third Parties

We may receive personal information from:

• Retailers, dealers and approved installers;
• Vehicle manufacturers, insurers and fleet operators;
• Employers and finance providers;
• Payment and delivery providers;
• Monitoring centres and recovery providers;
• Customer-support and fraud-prevention providers;
• Marketing, advertising and analytics platforms;
• App stores and social-media platforms;
• Public authorities and law-enforcement bodies;
• Professional advisers; and
• Other Road Angel Group companies.

Where you purchase a Road Angel product from a third party, we may receive information from that organisation or collect information directly from you during registration, onboarding, activation, installation or support.

5. How We Use Personal Information

5.1 Orders and transactions

• Process purchases and payments;
• Deliver products and arrange installation;
• Provide invoices;
• Manage subscriptions and renewals;
• Process returns, refunds and cancellations; and
• Prevent duplicate or fraudulent transactions.

5.2 Accounts and subscriptions

• Create and maintain accounts;
• Verify identity;
• Register and activate devices;
• Link devices to accounts;
• Manage subscriptions;
• Reset login details; and
• Protect account security.

5.3 Customer service

• Respond to enquiries;
• Provide technical assistance;
• Diagnose faults;
• Manage warranties and replacements;
• Handle complaints;
• Provide installation support; and
• Maintain customer-service records.

5.4 Products and connected services

• Operate devices and applications;
• Provide GPS, speed-awareness and cloud features;
• Provide connected-camera and subscription services;
• Deliver alerts;
• Maintain device connectivity;
• Provide firmware and software updates;
• Monitor technical performance; and
• Improve reliability and compatibility.

5.5 Tracker activation, monitoring and recovery

• Register and activate trackers;
• Verify the correct vehicle installation;
• Link the customer, vehicle and tracker;
• Administer monitoring services;
• Monitor device status;
• Identify suspected theft or unauthorised movement;
• Contact customers or nominated contacts;
• Investigate alerts and support recovery;
• Communicate with monitoring centres, recovery providers, insurers and police;
• Produce installation or insurance certificates; and
• Maintain an audit trail.

5.6 Fraud, theft and security

• Detect and prevent fraud;
• Investigate theft and misuse;
• Protect customers, property and systems;
• Verify identities;
• Monitor suspicious activity; and
• Cooperate with lawful investigations.

5.7 Product development

• Understand product usage;
• Improve devices, websites and applications;
• Develop new products and services;
• Test functionality;
• Analyse technical faults;
• Improve customer support; and
• Conduct reporting, research and statistical analysis.

5.8 Marketing

Where permitted by law, we may send product news, offers, renewal reminders, promotions, competitions, surveys and event information. You may opt out at any time.

5.9 Legal and regulatory purposes

• Comply with legal obligations;
• Respond to courts, regulators and lawful requests;
• Assist police and law-enforcement bodies;
• Maintain accounting and tax records;
• Enforce contracts;
• Resolve disputes; and
• Establish, exercise or defend legal claims.

6. Lawful Bases for Processing

6.1 Contract

We process information where necessary to enter into or perform a contract, including processing orders, delivering products, activating devices, providing installation, operating subscriptions, running tracker services and providing support.

6.2 Legitimate interests

Our legitimate interests may include:

• Operating and improving our business;
• Providing secure and reliable products;
• Maintaining accurate customer and installation records;
• Preventing fraud and theft;
• Supporting vehicle recovery;
• Protecting customers, property and systems;
• Understanding product performance;
• Improving customer service;
• Managing complaints;
• Direct marketing where permitted; and
• Protecting our legal rights.

6.3 Legal obligation

We may process information to comply with data-protection, consumer, tax, accounting, product-safety, regulatory and court requirements.

6.4 Consent

We may rely on consent for optional marketing, non-essential cookies, certain application permissions and optional connected functionality. You may withdraw consent at any time.

6.5 Vital interests

In exceptional circumstances, we may process or share information where necessary to protect someone’s life or physical safety.

7. Product Registration, Installation and Electronic Signatures

Where you complete a product-registration, installation or onboarding form, the information provided will be used to register and administer the product or service.

Typed names, electronic confirmations or signatures may be retained as evidence that information was confirmed, an installation was completed, a device was linked to a vehicle, relevant information was provided or an instruction was given.

8. Tracker Location and Monitoring Services

Tracker services may involve continuous or periodic processing of vehicle and device-location information.

The tracker may transmit information when:

• The vehicle moves;
• The ignition is switched on or off;
• An impact is detected;
• The tracker is disconnected;
• Power is interrupted;
• The vehicle is towed;
• A geofence is entered or exited;
• An authorised driver tag is not detected;
• A theft or movement alert is generated; or
• The customer requests location or journey information.

9. Dash Cams and Connected Cameras

Road Angel dash cams and connected cameras may capture identifiable people, vehicles and locations.

Where cloud or connected functionality is enabled, recordings or event clips may be uploaded to Road Angel or an authorised cloud provider.

We may process uploaded footage to:

• Provide cloud storage;
• Allow customer access to recordings;
• Protect event footage;
• Provide technical support;
• Investigate incidents;
• Provide footage to insurers or police at the customer’s request or where legally required; and
• Operate connected safety or claims services.

10. Call Recording

Telephone calls to or from Road Angel may be recorded for:

• Staff training;
• Quality monitoring;
• Confirming instructions;
• Customer service;
• Security and fraud prevention;
• Complaint investigation;
• Dispute resolution;
• Regulatory compliance; and
• Legal claims.

Where a call recording contains the personal information of other people, we may redact, extract or transcribe information where necessary to protect their rights.

11. Sharing Personal Information

We do not sell personal information.

11.1 Road Angel Group companies

Information may be shared between group companies for account administration, support, delivery, technical services, security, reporting and legal purposes.

11.2 Retailers, dealers and installers

We may share relevant information with retailers, authorised dealers, approved installers, mobile fitting providers and vehicle manufacturers where necessary.

11.3 Monitoring and recovery providers

For tracker services, we may share information with monitoring centres, recovery providers, security providers, insurers, police and law-enforcement bodies.

11.4 Service providers

• Website and ecommerce hosting;
• Payment and delivery services;
• Cloud hosting and data storage;
• CRM and customer support;
• Call handling and recording;
• Email, SMS and app hosting;
• Mapping and analytics;
• Marketing and fraud prevention;
• Cybersecurity;
• Installation and repairs;
• Warranty services; and
• Professional advice.

11.5 Authorities and advisers

We may share information with courts, regulators, government authorities, police, insurers, auditors, accountants, solicitors and other professional advisers where necessary.

11.6 Business transactions

If all or part of the business is sold, merged, reorganised, financed or transferred, personal information may be shared with relevant parties subject to appropriate protections.

12. International Data Transfers

Some suppliers or systems may process information outside the United Kingdom or European Economic Area.

Where required, we use safeguards such as:

• UK adequacy regulations;
• European Commission adequacy decisions;
• The UK International Data Transfer Agreement;
• The UK Addendum to the Standard Contractual Clauses;
• Standard Contractual Clauses; or
• Another legally recognised transfer mechanism.

13. How Long We Retain Information

We retain information only for as long as reasonably necessary, taking account of the nature of the information, the product or service involved, the duration of the customer relationship, legal duties, complaints, security and legal claims.

Orders and transactions

Order, invoice, payment and accounting records may be retained for up to seven years after the relevant financial period or transaction.

Accounts and subscriptions

Account and subscription information may be retained for the duration of the account or subscription and for an appropriate period afterwards.

Tracker installation and onboarding records

Tracker installation, vehicle, device, activation and onboarding records may be retained for the duration of the tracker service or customer relationship and for an appropriate period afterwards.

Location and journey information

Location, journey and movement information is retained for the period necessary to provide the relevant service. Information linked to an active theft, recovery, complaint, claim or investigation may be retained for longer.

Call recordings

Call recordings are retained for a limited period according to their purpose and may be kept for longer where they relate to a complaint, dispute, fraud, security incident, regulatory matter or legal claim.

Customer support

Support tickets, complaint records and related communications may normally be retained for up to three years after closure, or longer where necessary.

Marketing

Marketing preferences are retained until consent is withdrawn, an objection is made or the information is no longer required. A minimal suppression record may be retained to honour an opt-out.

14. Security

We use technical and organisational measures designed to protect personal information, including:

• Encryption and secure connections;
• Access controls and authentication;
• Password protection;
• Role-based permissions;
• Logging and monitoring;
• Network security;
• Staff training;
• Supplier due diligence;
• Incident-response procedures;
• Backup controls; and
• Physical security.

15. Your Data-Protection Rights

Depending on the circumstances, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request completion of incomplete information;
• Request deletion;
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Withdraw consent;
• Request transfer of qualifying information;
• Request details of international-transfer safeguards; and
• Complain to a supervisory authority.

These rights are not absolute and may be subject to legal exemptions.

16. Subject Access Requests and Call Recordings

A request for access to personal information is commonly known as a Data Subject Access Request or DSAR.

A valid request may cover:

• Customer and account records;
• Onboarding forms;
• Device and vehicle information;
• Support records;
• Emails and complaints;
• Call recordings; and
• Relevant internal notes.

We may redact or withhold information where necessary to protect the rights of another person, preserve legal privilege or apply another lawful exemption.

17. Automated Decision-Making

We do not ordinarily make decisions producing legal or similarly significant effects solely through automated processing.

Automated systems may be used to detect fraud, identify unusual activity, trigger device alerts, generate theft or movement alerts, prioritise technical issues, personalise website content or select marketing audiences.

18. Marketing Communications

We may send marketing where you have consented, where the law permits marketing to an existing customer or where another lawful basis applies.

You can stop marketing by using an unsubscribe link, replying to an SMS where available, updating preferences or contacting us.

Operational and service messages are not marketing and may include order, subscription, activation, security, theft, movement, recovery, safety, firmware and legal notices.

19. Children

Road Angel products and services are not directed at children under 16. We do not knowingly create accounts for children or intentionally collect their information without an appropriate lawful basis.

20. Third-Party Websites, Retailers and Services

Our websites and applications may link to third-party services. We are not responsible for the privacy practices of independent third parties.

Where a complaint concerns an original purchase from an independent retailer, that retailer may be responsible for the sale, payment, refund or contractual issue. Road Angel remains responsible for information Road Angel itself collects and processes.

21. Cookie Policy

21.1 What are cookies?

Cookies are small text files placed on a computer, phone, tablet or other device when a website is visited.

21.2 Strictly necessary cookies

These cookies support baskets, checkout, secure login, authentication, fraud prevention, security and essential website functions.

21.3 Functional cookies

These cookies remember choices such as language, region, login preferences, display preferences and recently viewed products.

21.4 Analytics cookies

These cookies help us understand website use, page visits, navigation, errors, campaign performance and opportunities to improve the website.

21.5 Advertising and marketing cookies

These cookies may be used to show relevant advertising, limit frequency, measure performance, attribute sales and create advertising audiences.

21.6 Social-media cookies

Social-media services may place cookies where embedded content, videos, sharing buttons or integrations are used.

21.7 Cookie providers

Depending on the technologies in use, providers may include:

• Shopify;
• Google;
• Meta;
• Microsoft;
• TikTok;
• Klaviyo;
• Affiliate networks;
• Payment providers;
• Customer-support providers; and
• Fraud-prevention providers.

21.8 Managing cookies

You can manage non-essential cookies through the cookie-consent banner or your browser settings. Blocking some cookies may affect checkout, account login, basket functions or other website features.

22. Complaints

If you are concerned about how we use personal information, please contact us first at privacy@roadangelgroup.com.

You also have the right to complain to the Information Commissioner’s Office. If you are in the European Economic Area, you may also complain to your local supervisory authority.

23. Contact Details

24. Changes to This Policy

We may update this policy to reflect changes to our products, services, suppliers, technology, legal requirements or processing activities.

The latest version will be published on our website with an updated revision date. Where a change materially affects how we use personal information, we may provide an additional notice.