The Motorhome and Campervan Hire Specialists
Nuvolla limited, trading as Spirit of Freedom is the owner and operator of www.spiritoffreedom.co.uk. We are a limited company operating under company number 5601770. Our registered company address is: 32 Thorpe Road, Peterborough PE3 6SR. Should you wish to contact us please call 01780 ******
Spirit of Freedom are committed to protecting and respecting your privacy.
For the purpose of compliance with UK data protection law, the data controller is Nuvolla Limited and the Data Protection Officer is our nominated person for data protection.
Your personal data, that is any information which identifies you, or which can be identified as relating to you personally, for example, and not limited to: name, address, phone number, email address, will be collected and used by us.
We obtain personal information from you when you enquire about our activities, send or receive email, purchase products, ask a question or otherwise provide us with personal information.
We collect personal data in connection with specific activities such as: placing an order & booking holidays
Examples of ways that you may share your personal data with us are by:
• completing electronic and paper forms
• registering to use our website
• entering a competition, promotion or survey
• corresponding with us by phone, email, social media or letter
• buying services from us
• responding to an SMS message
The personal information we collect will depend on the nature of the data processing requirement. For example, it might include name, date of birth, email address, postal address, telephone number and bank account details. Although we may take credit/debit card information to complete a transaction, we do not store this information.
We are required to collect information about your risk factors, including your claim history, relating to the insurance policy we need to put in place, to provide you with cover whilst driving one of our vehicles.
Depending on your relationship with us, we will use your personal information for the following purposes:
• to provide you with the services, products or information you have requested
• to provide online technical support should you encounter a problem with our digital services
• for investigation purposes if there is a suspected misuse of our digital services
• to enable you to transact within certain areas of our digital services and perform activities such as make site bookings or complete enquiry forms
• for general administration purposes, such as handling your enquiries and managing purchases of products and services
• to carry out research into the market for our services
• to comply with statutory and regulatory compliance
• to assess insurance risk and to prevent and detect fraud
Where relevant, we may also assess your personal information for the purposes of fraud and credit risk reduction.
If you enter your contact details in one of our online registration forms, we may use this information to contact you even if you do not “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our digital services.
We may need to share your information with our service providers, associated organisations and agents for the purposes described above but we never sell your information to other organisations.
We know it is important to our website visitors to provide the best, tailored service possible. To help us do this, we use automated profiling and targeting to understand our customers’ requirements and make sure that:
• our communications (e.g. emails) and services (e.g. our website) are relevant, personalised and interesting to you, and
To do this we’ll analyse how you interact with us on our website and other websites you may visit through use of data from site bookings and use both geographic and demographic information to let you know what’s happening in your local area, nationwide and overseas and better understand your interests. We use specific tools, such as Google Analytics to look at how you interact with us online. Much of the information we collect is aggregated, however we may also collect some personal data for the use of personalising your experience, optimising our marketing campaigns, and to ensure the website site is functioning as intended.
We carry out research to generate feedback on your experiences with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you. If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. We may share your personal data, e.g. contact information, to a third party data processor who will carry out research on our behalf, but only for the purpose explained here.
All pages within our website are protected by encryption and we also use secure third party payments services when you make a payment via our digital services. We take appropriate measures to safeguard personal information that is disclosed to us and keep it secure, accurate and up to date.
Our operations are based in the UK and we store most of our data on secure cloud based services.
As indicated above, we may pass your information to our service providers, agents and associated organisations for the purposes explained above.
We may share information with 3rd parties, to enable us to provide you with the service you have requested, where relevant, which would include:
• affiliated sites
• insurance underwriters
• insurance administrators
• overseas travel and ferry companies
• financial transaction providers
• infrastructure service providers
• contractors working for Spirit of Freedom in an operational capacity
• cloud service providers
• data storage
• subcontractors we appoint to provide services to you, for example breakdown recovery mechanics
We may also need to disclose your information if required by law, for example to government bodies and law enforcement agencies, or if we have your permission to do so.
We will not sell any personal data or your web browsing activity to a third party.
Collecting, processing and using personal data is permitted only under a lawful basis. The lawful bases that we operate under are listed below, along with the data processing activities that fall under them.
• Necessary for the performance of a contract
When you become a customer and provide us with your personal data, certain processing activities are considered necessary for the performance of the contract between you and us. This includes activities such as registering you as a customer, administering your insurance policy, analysing and researching your individual membership requirements and booking sites
When you buy goods or services from us we will process your personal data where this is necessary for us to provide you with those goods or services, including by sharing your data with third parties involved in providing the goods or services to you.
• Legitimate interests
We will contact you with offers and services. The lawful basis with which we use your personal data in this way is legitimate interests. This is because on balance, and taking account of your own interests, we have determined that the data processing is necessary for the legitimate business interests of our company. We also process your data where this is necessary for our administration of our business and to manage our relationship and correspondence with you, on the basis that we have a legitimate interest in doing this.
• Legal obligations
There are circumstances when we are required to process personal data in order to meet our legal obligations. Processing data under this basis can relate to financial data, insurance claims information and HMRC reporting requirements. When processing on the basis of legal obligations, you have no right to erasure or right to object.
We rely on the lawful basis of consent to process personal data, it must be freely given, specific, informed, and must be an unambiguous indication of agreement. If you have provided consent you have the right to withdraw it at any time. We would require your consent to process special category data unless processing data under the lawful basis of protecting vital interests.
When we process special category data we rely on one of the lawful bases outlined above as well as one of the following legal bases, which apply to special category data:
(a) Your explicit consent
In some circumstances, we provide you with the opportunity to voluntarily inform us of your special category data, e.g. whether or not you have a disability, so that we can help you with the allocation of an appropriate pitch at a site. In these situations if you choose to provide the information we rely on your explicit consent as our basis for processing.
We may also ask you to consent to us using your special category data to ensure that we can provide you with the most appropriate insurance services. Please note that if we need your consent to process special category data in order to provide a service and you decide not to give consent or you later withdraw consent we will not be able to provide the service.
(b) Where processing is necessary for reasons of substantial public interest
In some situations it may be necessary for reasons of substantial public interest for us to process special category data, for example in relation to the administration and underwriting of insurance or to prevent or detect insurance fraud. We only do this where the processing is permitted by laws that provide safeguards for your rights.
(c) Where processing is necessary for establishing, exercising, or defending legal claims
If it is necessary for us to process your special category data to establish, exercise, or defend a legal claim. This could happen, for instance, if there is a legal claim relating to an insurance policy you hold with us.
We retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each data type, taking into account the reasons that the personal data was obtained, but if relevant, the length of retention is determined in a manner consistent with legal and regulatory obligations.
We operate a Data Retention Policy and Schedule that sets out retention periods for the different kinds of data we might hold about you.
Under UK data protection law, a data subject is considered to be ‘an individual who is the subject of personal data’. Data subjects have certain rights and by exercising these rights, you can make requests regarding your personal data to us. A summary of these rights is explained below.
The Supervisory Authority that regulates and enforces data protection law in the UK is the Information Commissioner’s Office (ICO) and additional information and guidance about these data subject rights can be found on their website as follows https://ico.org.uk/.
• Right to be informed
At the point of collecting personal data from you, we must provide you with information such as the purpose and rationale for the processing of that data.
• Right of access
This right provides you with the ability to access to your personal data that is being processed by us. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your requested personal data. The information will be provided free of charge unless the request is manifestly unfounded or excessive; in those cases, the request may be refused or a reasonable fee charged.
• Right to rectification
This right provides you with the ability to ask for modifications and rectification to your personal data in the event you believe that your personal data is not up to date or accurate.
• Right to erasure
Also known as ‘the right to be forgotten’ this right, under certain circumstances, provides you with the ability to ask for the deletion of your personal data. We may refuse to fulfil the right to erasure if there is legal reason why the personal data must be retained, the grounds are not valid or if the data is required for use in the defence of a legal claim.
• Right to restriction of processing
You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction. This may be because you have concerns with the personal data we hold about you or how we have processed your data. In most cases we will not be required to restrict your personal data indefinitely, but will need to have the restriction in place for a certain period of time.
• Right to data portability
This right provides you with the ability to ask for a copy of or a transfer of your personal data, in a certain format. You may ask for your personal data to be provided back to you or transferred to another data controller. When doing so, the personal data must be provided or transferred in a structured, commonly used and machine-readable format.
• Right to object
You have the right to object to us processing your personal data, including marketing activities and profiling, on grounds relating to your particular situation. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
To make the request process easy for you and to ensure we have all the information we need to be able to fulfil your request, you can complete our request form.
If you would prefer to make a request verbally, you can call us on 01780 ******
Once we have all the information necessary to respond to your request and have confirmed your identity, we’ll locate your information and manage your request without undue delay and in any event within one calendar month. Note that this timeframe may be extended by two further months if your request is particularly complex or there is a large volume of requests.
We are compliant with the Payment Card Industry Data Security Standard (PCI DSS). This is the international standard for secure credit and debit card payment processes and means that when you pay for goods or services from us using a debit or credit card, the relevant technical and operational security requirements are in place to protect the account data.
If you think your data has been misused or that we haven’t kept it secure, please contact us using the contact details provided in section 1 and we will investigate any concerns you may have. If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO).
The telephone number for the ICO Helpline is 0303 123 1113.
The ICO can investigate your claim and take action against anyone who has misused personal data. You can also visit their website for information at https://ico.org.uk/concerns/.