Privacy policy

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain
• How the app handles information

Drive Everywhere is made by Richard Kielty, who is responsible for the personal information described in this notice (the controller). “We” and “us” in this notice mean Richard Kielty.

Email: privacy@driveeverywhere.co.uk

For help with the app, email support@driveeverywhere.co.uk.

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Correspondence
• Screenshots
• Device and app details, such as iPhone model, iOS version and app version
• Feedback, comments and crash reports sent by testers through TestFlight, and testers’ names and email addresses
• App Store ratings and reviews

Please don’t send us information about your students, or about anyone’s health. If it reaches us anyway, we use it only to deal with your message, and delete it as soon as we notice it.

We collect or use the following information for app improvements, only if you agree to share usage and crash data in the app:

• IP addresses, and the approximate location worked out from them
• App user journey information
• A random identifier for each installation of the app
• Device and app details, such as iPhone model, iOS version and app version
• Crash reports
• Performance measurements, such as how quickly the app starts and responds

We collect or use the following information for running and protecting our website:

• IP addresses
• Browser and device details

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • To reply to people who contact us, help them use the app, investigate and fix the problems they report, and deal with any complaint or claim. We use only what they send us, and delete it within 30 days of their query being resolved.
  • To invite people to test new versions of the app before release, and to use their feedback to find and fix problems. We use only what testers send us through TestFlight, and delete feedback within 30 days of it being dealt with.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for app improvements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. To withdraw it, turn off Share Usage and Crash Data in the app’s Settings, under Privacy.

Our lawful bases for collecting or using personal information for running and protecting our website are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • To run our website and protect it from misuse.

• Directly from you
• Suppliers and service providers
• Driving instructors, if they include information about their students when they contact us.

For information on how long we keep personal information, see our retention schedule at https://driveeverywhere.co.uk/data-retention/

Data processors

Google LLC (Firebase), United States

This data processor does the following activities for us: They provide the analytics, crash reporting and performance monitoring in our app (Google Analytics for Firebase, Crashlytics and Performance Monitoring) for people who agree to share it, and host our website (Firebase Hosting). They collect and store this on our behalf, and we use it only to find and fix problems and improve the app. See Privacy and security in Firebase and Google’s privacy policy.

Google LLC (Google Workspace), United States

This data processor does the following activities for us: They provide our email, including the support and privacy addresses, and store the messages we send and receive. See Google Workspace security and privacy and Google’s data processing terms.

Apple Inc. (App Store Connect and TestFlight), United States

This data processor does the following activities for us: They distribute our app and its test versions, and pass us the feedback, screenshots and comments testers send through TestFlight, testers’ names and email addresses, and App Store ratings and reviews. We use these to test the app, answer feedback and fix problems. See Apple’s privacy policy and the App Store and privacy.

Others we share personal information with

• Professional or legal advisors
• Organisations we’re legally obliged to share personal information with

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

Organisation name: Google LLC

Category of recipient: Cloud service provider: app analytics, crash reporting, performance monitoring, website hosting and email

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge). Google LLC is on the Data Privacy Framework list.

Organisation name: Apple Inc. (through Apple Distribution International Limited, Ireland)

Category of recipient: App distribution and beta testing platform (App Store Connect and TestFlight)

Country the personal information is sent to: United States, and Ireland

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

Organisation name: Google LLC’s affiliates and subprocessors

Category of recipient: Data centre, infrastructure and technical support providers used to run Firebase and Google Workspace

Country the personal information is sent to: Worldwide, including the United States and countries in the European Economic Area and Asia, as listed in Google’s subprocessor lists for Firebase and Google Workspace

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Apple Inc.’s affiliates and subprocessors

Category of recipient: Data centre, infrastructure and technical support providers used to run App Store Connect and TestFlight

Country the personal information is sent to: Worldwide, including the United States and countries in the European Economic Area

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

The ICO explains international transfers in more detail.

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: privacy@driveeverywhere.co.uk

You can view our data protection complaints procedure at this link: https://driveeverywhere.co.uk/complaints/

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
ICO Head Office
4th Floor, No.3 Circle Square
5 Hawkshaw Street
Manchester
M1 7BL

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

In short

Everything you enter, about you or your students, stays on your iPhone, unless you choose to email us for support. If you agree, the app also sends how it's used, crash reports and performance data to Google Firebase, to help find and fix problems; none of it includes what you've entered.

What the app keeps

Your students (their names, phone numbers, pickup addresses, dates of birth, emergency contacts, whether you've checked their provisional licence and any photo of it, their theory test, and their status), your lessons and other events, the payments you record, your name, and your settings. They're kept on your iPhone so they're there next time you open the app, and they're never sent to us or to Firebase.

Your students' information

You decide what to record about your students, and it stays with you. As it's kept only on your device, it's yours to look after under data protection law: letting your students know what you keep and why, keeping it accurate, deleting it when you no longer need it, and keeping your iPhone secure with a passcode. Take extra care with information about anyone under 18, and with anything about a student's health, such as a learning difficulty. The ICO has guidance for small businesses.

No accounts or adverts

There's no sign-in and no advertising, and nothing the app collects is used to track you across other apps or websites.

Usage, crash and performance data

The first time you open the app, it asks whether to share this. If you agree, it sends Google Firebase (Analytics, Crashlytics and Performance Monitoring) which screens you open and roughly how you use them, details of any crash, and how quickly the app starts and responds, along with your iPhone's model, iOS version, the app's version, your region and a random identifier for this installation of the app. It never includes your students, lessons, payments, name or anything else you enter, and it isn't used for advertising.

If you don't agree, nothing is sent. You can change your mind at any time in the app's Settings, under Privacy. If the app can't find your answer (after you reinstall it, say), it asks again.

Maps and addresses

When you search for a pickup address, what you type is sent to Apple Maps to find matching places, and the map is loaded from Apple. Apple handles this according to its own privacy policy, and nothing else about you or your student is sent with it.

Your location

If you allow it, your location is used only while you're setting a pickup address, to start the map where you are. It isn't kept or sent anywhere by the app.

Camera and photos

The camera is used only when you scan a student's provisional licence, and the photo library only when you choose a photo of it. The photo is kept in the app, on your device, and adding one is optional.

Phone calls

Tapping a phone number opens your Phone app to call it. The app doesn't see or keep your calls.

Ratings

Asking to rate the app shows Apple's rating prompt. Ratings and reviews are handled by Apple; the app doesn't see who you are or what you rate.

This website

This website has no cookies, analytics, adverts or third-party scripts, and its fonts are served from here.

Backups

Like other apps' data, what the app keeps can be included in your iPhone's own backups (to iCloud or a computer), which Apple handles according to your settings.

Removing information

You can delete a lesson, a payment or a licence photo in the app. Deleting the app removes everything it has kept.

Changes

If this policy changes, the new version will be published here, with the date it changed.