Privacy policy

WHAT YOU CAN EXPECT TO SEE FROM READING THIS PRIVACY POLICY
Liquid is an InMotion Ventures Limited (IMV) company. IMV is a subsidiary of Jaguar Land Rover Limited (JLR). JLR is part of a group of companies whose parent company is Jaguar Land Rover Automotive plc. JLR is part of the Tata group. More information about IMV, JLR and Tata can be found here:
www.inmotionventures.com
www.jaguarlandrover.com
www.tata.com

We respect the privacy of every individual who visits our websites and apps. This Privacy Policy explains how we use personal data received from our websites and apps, and informs you of your data protection rights. We will also help you to know when there is new information available in this Policy. We will tell you when this Privacy Policy was last updated, so you can take time to read it if it has changed since your last visit. Privacy Policy Last Updated: 4th September 2018.

DATA PROTECTION – WHAT YOU SHOULD KNOW WHO WE ARE AND WHAT IS COVERED BY THIS PRIVACY POLICY
Who We Are: When we refer to ‘Liquid’, ‘InMotion Ventures’ ‘we’ ‘our’ or ‘us’ in this Privacy Policy, we refer to: InMotion Ventures 2 Limited, whose registered office is at: Abbey Road, Whitley, Coventry CV3 4LF, and whose registered number is: 10444740.
What this Privacy Policy covers: This Privacy Policy covers the Liquid website at www.liquid.auto, and the Liquid iPhone app (downloadable from https://itunes.apple.com/gb/app/liquid-car-rental/id1355354261). To be transparent, when you visit other IMV or JLR websites and apps not covered by this Privacy Policy, these may be controlled by other JLR group entities, or by  a third party acting on our group’s behalf. We encourage you to check the Privacy Policy for the website or app you are visiting to see its privacy policy terms.              

How we’re regulated: For UK data protection legislation purposes, Jaguar Land Rover Limited is registered with the Information Commissioner’s Office under registration number ZA020510. Contact details: If you’d like to get in touch with a website or app-related query, please email contact@liquid.auto

WHAT INFORMATION WE COLLECT FROM  OUR WEBSITE OR APP AND WHAT INFORMATION WE RECEIVE FROM OTHER SOURCES.
Our website and app offer a number of functions that collect information you provide to us when you ask to be kept informed, to be added to lists, events or experiences, or when you buy goods or book or request services. Our website and app also help you better understand our products and services.

The main ways we collect information:
When you visit, or use and interact with our website or app;
When you provide information to us;
When you contact us (via contact details made available on our website and in our app), or send us correspondence.

Please see the “Tell me more” box below to find out more about the data we may receive from you directly.

Information may also be received from other sources. For example:
Third party support services: For the performance of our services and to allow us to maintain appropriate records and to support ongoing queries, we may receive data about you or your website and app activities from our group companies or third party providers (e.g. to confirm payments, to track deliveries, to support maintenance). More information on our categories of suppliers is provided at Section 4 (Who we share personal data with) below.
Device data: Our website and app automatically take certain device information in order to optimise your experience (for example, allowing our website to automatically adapt screen size as appropriate for the device you are using to browse the website). This data also supports our analytics. More information on automated data collection and cookies can be found in our Cookies policy, available at the end of this policy.
Marketing data: Your contact details, marketing preferences or other information may be shared with us by Jaguar Land Rover Limited, retailers or other third parties and partners, where there is appropriate notice and in compliance with applicable data protection laws. You have the right to ask us not to use your personal data for marketing purposes. Please see your data protection rights at Section 7 (Your data protection rights) below for further information on these.
Public sources of data: We may use public sources of data, for example, to support website and app functionality (e.g. to support authenticate or fraud checks), and/or to maintain the accuracy of the data we hold. For example, we may make checks from time to time with the DVLA to check our vehicle owner information remains up to date or to confirm your suitability for vehicle hire by checking whether you have received any endorsements on your driving licence.

TELL ME MORE about the personal data we may receive direct
We receive information you provide to us in your use of our website or app, for example, when you add information to online forms or to data fields. We may also receive information from you by other online means, for example, if you comment on our social media pages. This will be the information that is visible to you, and may include your name, occupation, contact information (e.g. email, postal address and phone/mobile number), credit card/payment details, driving licence details, vehicle data and general information you decide to share such as your experience with our products and services. We may also collect other information relating to the status, maintenance, performance and use of the vehicle.

HOW WE USE YOUR PERSONAL DATA.
We use personal data to manage and meet service and information requests, to understand service, vehicle and website and app use, to use data analytics to improve our products and services, marketing, customer relationships and experiences, to make suggestions and recommendations to you about goods or services that we feel may interest you and to make our products and services (including our web services) as effective as possible. For more information on our processing, and the legal grounds that are relevant, please see the “Tell me more” section below.

TELL ME MORE
The main uses of your personal data and the legal grounds we rely on for these are:

Activity: Maintaining and supporting website and app use
Where you use an online service governed by our provided online Terms and Conditions (for example, purchases from the online stores, or entering into prize draws and competitions), we and our permitted third parties will process data in a number of ways that support our website and app services. For example, this may include the following activities:  identity confirmation, any fraud and authentication checks, service delivery, administration of prize draws, competitions, membership offers, surveys and other promotional  activities, any applicable payment processes and collections activities, customer support and any ongoing service communications. We may also seek to improve our services, using user experiences to strengthen our internal processes.
Applicable Legal grounds: Necessary for contract; Legitimate Interests in running effective website and app servicesWhere personal data is required for entering into a contract, we will identify to you where information is mandatory. The consequences of not providing this information may include being unable to proceed with the requested service.

Activity: Managing your requests
We will process data in managing your requests made on or via our websites and app (e.g. where you sign up for our newsletter or add your details into any other data form or data field). We will also process data in providing and maintaining personalised website and app experiences.
Applicable Legal grounds: Legitimate Interests in running effective website and app services

Activity: Enhancing website and app experience
Where we pre-fill website and app data fields to enhance and streamline your online experience.
Applicable Legal grounds: Legitimate Interests in enhancing, simplifying and streamlining website and app experiences.

Activity: Internal research and development
For internal research, development, analytics, analysis and reporting purposes, e.g.  to monitor current vehicle use, performance and maintenance requirements, predict trends or performance, develop new functions, products and services, or to evidence compliance with regulatory requirements.
Applicable Legal grounds: Legitimate Interests in assessing and improving performance, managing compliance, monitoring trends and developing new products. Legitimate interests in defining types of customers for our products and services and to develop and inform our marketing strategy.

Activity: Marketing activities
We will obtain your consent to market communications to you using electronic means (e.g. email, text etc.), and may share your details for electronic marketing communications with our network of independent third parties, where you give consent for this to happen. We will also comply with cookie obligations where we use cookies on our website and app.
Other marketing activities will happen assessed on the Legitimate Interests ground. e.g. where we tailor marketing communications or send targeted marketing messages via post or social media and other third party platforms; and in providing existing customers with information about similar products and services or products or services that we believe may interest you based on other customers' information. In order to improve the services we offer via our websites and app, we may ask you to participate in research from time to time. It is entirely up to you whether you choose to do so.
We will use profiling and carry out research and analytics activities to inform our marketing strategies, to create a better understanding of our customers and visitors;  to support our website and app advertising, and to better improve the website and app information, functionality  and the services we provide or recommend.
Applicable Legal grounds: Consent; Legitimate Interests for direct marketing purposes  Note: Where we collect your personal data with consent, you may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 7 below for further details. (This right doesn’t effect the lawfulness of processing that was based on that consent before its withdrawal.)

Activity: Records maintenance and general administration
To maintain our records, administer and maintain our websites and app, support your queries and any other internal operations and administrative purposes (for example, this will include troubleshooting, testing,  supporting our audit requirements and in responding to any enquiries you may make, including any data protection rights you raise).
Applicable Legal grounds: Legitimate Interests in maintaining appropriate websites/apps, records and service administration

Activity: Network and information security
To maintain our network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access. And to maintain appropriate server locations (for example, we may  work with third parties to support appropriate use of cloud services).
Applicable Legal grounds: Legitimate Interests as appropriate for ensuring network and information security

Activity: Corporate acquisitions and disposals
Applicable Legal grounds: Any data processed as is necessary in the context of corporate acquisitions or disposalsApplicable Legal grounds: Legitimate business Interests; Legal Obligation

Activity: Management of legal and regulatory requirements
To manage legal and regulatory requests and requirements, meet or defend legal rights or for the prevention/detection of crime, (including where required to assist HMRC, law enforcement agencies such as the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body, or for the safeguarding of national security). To confirm your suitability for vehicle hire and ensure the validity of our insurance.
Applicable Legal grounds: Legitimate Interests in complying with law, the terms of our insuranceand regulation, including responding to regulators; Legal Obligation

Activity: Service communications In the event we communicate to you an urgent safety or product recall notice.
Applicable Legal grounds: Vital interests; Legal Obligation

WHO WE SHARE PERSONAL DATA WITH.
We may share your personal data with:
Those third parties who need to handle it so we can provide to you the products, services you have signed up to or requested, for example, to provide or offer finance or credit, insurance, to provide marketing and advertising support services and for optimised website services.

Jaguar Land Rover group companies in line with the data uses set out in this Privacy Policy.

Third parties in the event we sell or buy any business or assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or requests, or in order to enforce these terms or to investigate actual or suspected breaches.
We have safeguards in place with our service providers to ensure that your data is kept securely and used in accordance with the purposes set out in this Privacy Policy.

TELL ME MORE About Suppliers
We use a number of service suppliers to support our business and these service providers may have access to our systems and data in order to provide services to us and on your behalf, for example payment processors, information technology such as hosting service providers, marketing and digital advertising support services, customer services and relationship handling, service and system specialists, website analytics support, and support for events.
About JLR Group companies, and how they may provide service support

As a member of the Tata Group of companies, we can benefit from the large IT infrastructure and expertise that exists within our wider corporate structure. This means that the personal data you provide to us may be accessed by members of our group of companies only as necessary for service and system maintenance and support, aggregate analytics, business continuity, IT and administrative purposes. For example where necessary to support particular website enquiries, or to provide technical support that maintains website functionality.

About Public bodies, law enforcement and regulatorsFrom time to time, the police, other law enforcement agencies and regulators can request personal data, for example for the purposes of preventing or detecting crime, or apprehending or prosecuting offenders.

INFORMATION ABOUT INTERNATIONAL DATA TRANSFERS.
The Liquid website and app use servers which are hosted in the EU. However we may share personal data with suppliers or group companies located outside of the EU where this is necessary for the purposes described above. Where this happens, JLR applies safeguards to add to the data protections that apply to those data transfers. This includes an assessment of the adequacy of the third country in question, use of European Commission approved model contract terms where appropriate, and assessment of Privacy Shield certification for US located entities where applicable.

TELL ME MORE about the adequacy checks JLR puts in place for international data transfers …
Where JLR chooses to share personal data with a third party located outside the EU, the following factors are assessed to support adequate transfer of this data:-

Internal checks to identify the existence or absence of any adequacy decision by the European Commission. JLR has group companies, and use suppliers located in countries that have been approved by the European Commission as having essentially equivalent data protection laws. A full list of these countries as at the date of this Privacy Policy is: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel,  Switzerland, Jersey, New Zealand, Uruguay and the Isle of Man. (The European Commission has also approved as adequate the EU-US Privacy Shield programme – this is described below). This list and information about the protections the European Commission has considered is available via this link.
Use of measures like European Commission approved measures to support adequate transfers of personal data. JLR also has group companies, and use suppliers located in countries that are elsewhere in the world. To manage data protection compliance with these transfers, JLR uses European Commission approved data transfer mechanisms such as use of model contractual clauses approved by the Commission. JLR will also assess where applicable where a supplier is able to demonstrate to us they have Binding Corporate Rules. (Binding Corporate Rules is a GDPR – recognised Data Protection mechanism to ensure adequate personal data transfers). JLR may work with suppliers who are able to demonstrate to us they are Privacy Shield certified.
To understand the protections required in European Commission approved Model Clauses, a template copy of these is accessible from this location.
To see a full list of approved Binding Corporate Rules, please click this link.
A full list of Privacy Shield participants, and their Privacy Shield certification information is available from this website link.

HOW LONG WE HOLD PERSONAL DATA FOR.
We’ll keep your personal data for as long as we need it to provide the products and services you’ve signed up to. We may also keep it to comply with our legal obligations, respond to queries and resolve any disputes, to meet our legitimate interests and to enforce our rights.              

The criteria we use to determine storage periods include the following: Information we have told you about storage periods on our website/app or in our terms and conditions. We will also use criteria such as applicable contractual provisions that are in force, legal statutory limitation periods, applicable regulatory requirements and industry standards.

YOUR DATA PROTECTION RIGHTS.
You have rights in connection with your personal data, including: to withdraw consent where you have given it, to be informed and have access to your personal data, to correct or complete inaccurate data, and in certain circumstances to restrict, request erasure, object to processing, or request portability of your personal data to another organisation.We try to ensure that we deliver the best levels of customer service. if you do need or want to get in touch with us for any reason regarding your data protection rights, please get in touch using the email address below, and add into the subject header that it relates to your data protection rights contact@liquid.auto

If you are not satisfied, you also have the right to complain to the Information Commissioner’s Office.

To learn more about these data protection rights, see “Tell me more” below.  

TELL ME MORE
About my data subject rights
If you have given us consent to process your personal data, including for electronic marketing communications, you have the right to withdraw that consent at any time. Just use the unsubscribe options presented, for example, that are present in the email marketing communications sent by us.  

You can ask for access to the personal data we hold about you, object to the processing, request that we correct any mistakes, restrict or stop processing or delete it. If you do ask us to delete or stop processing it, we will not always be required to do so. If this is the case, we will explain why.

In certain circumstances you can ask us to provide you with your personal data in a usable electronic format and transmit it to a third party (right to data portability). This right only applies in certain circumstances. Where it does not apply, we will explain why.  

About how I can get in touch with the Information Commissioner’s Office (ICO)

The Information Commissioner’s Office (the ICO) is the supervisory authority that regulates personal data in the UK. You can get in touch with the ICO in any of the following ways:
By going to their website: www.ico.org.uk
By giving them a call on 0303 123 1113
Or by writing to them. Their address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF.

LINKS TO OTHER WEBSITES
Our website and app may contain links to other websites and apps run by other organisations which we do not control. This policy does not apply to those other websites and apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide) and we provide links to those websites and apps solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness.

KEEPING YOUR INFORMATION SECURE
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
We require all of our services providers to have appropriate measures in place to maintain the security of your information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet; any transmission is at your own risk. Your information will be kept in a secure environment protected by a combination of physical and technical measures such as encryption technologies or authentication systems to prevent any loss, misuse, alteration, disclosure, destruction, theft or unauthorised access.

ANNEX
For transparency, this Privacy Policy covers www.liquid.auto and the Liquid iPhone app (downloadable from https://itunes.apple.com/gb/app/liquid-car-rental/id1355354261), not all IMV and JLR websites and apps. We would always encourage you to click the Privacy Policy link of the website or app you are visiting to see the privacy information that applies.

LIQUID COOKIE POLICY
Our Site uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our site or app and also allows us to improve its performance. For detailed information on the cookies we use, the purposes for which we use them and to learn about how to manage cookies, please see below.
By continuing to browse our site or app, you are agreeing to our use of cookies.

INFORMATION ABOUT OUR USE OF COOKIES
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
You can find more information about the individual cookies we use and the purposes for which we use them below:—

Cookie Name: __utma, __utmb, __utmc, __utmt, __utmv, __utmz
Cookie Type: Persistent third party cookie
Purpose: These cookies enable the function of Google Analytics. This software helps us take and analyse visitor information such as browser usage, new visitor numbers, response to marketing activity and browsing times. That information helps us to improve the website and your experience, and to make our marketing campaigns relevant.These cookies can be turned off via your web browser, and will not affect the user’s experience.

Cookie Name:  id[.googleads.g.doubleclick.net]
Cookie Type:  Persistent third party cookie
Purpose:  Conversion tracking and remarketing, to allow us to run Google AdWords advertising campaigns.

Cookie Name: Facebook Pixel
Cookie Type:  Persistent third party cookie
Purpose:  Conversion tracking and retargeting, to allow us to run Facebook advertising campaigns.

Cookie Name:  .intercom.io
Cookie Type:  Persistent third party cookie
Purpose:  Intercom is a communication tool which allows users to interact with us via Live Chat

Cookie Name:  .hotjar.com
Cookie Type:  Persistent third party cookie
Purpose:  Analytics to enable to to understand how a user interacts with the Liquid website

Cookie Name:  .webflow.com
Cookie Type:  Persistent third party cookie
Purpose:  Webflow is used to construct the Liquid.auto website and cookies are used for internal Webflow metrics

MANAGING COOKIES – DISABLING AND ENABLING COOKIES
You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. Guideline instructions on how to check cookies are enabled follow below:

How to check cookies are enabled for PCs

Google Chrome
1. Click on ‘Tools’ at the top of your browser window and select Options
2. Click the ‘Under the Hood’ tab, locate the ‘Privacy’ section, and select the ‘Content settings’ button
3. Now select ‘Allow local data to be set’

Microsoft Internet Explorer 6.0, 7.0, 8.0
1. Click on ‘Tools’ at the top of your browser window and select ‘Internet options’, then click on the ‘Privacy’ tab
2. Ensure that your Privacy level is set to Medium or below, which will enable cookies in your browser
3. Settings above Medium will disable cookies

Mozilla Firefox
1. Click on ‘Tools’ at the top of your browser window and select Options
2. Then select the Privacy icon
3. Click on Cookies, then select ‘allow sites to set cookies’

Safari
1. Click on the Cog icon at the top of your browser window and select the ‘Preferences’ option
2. Click on ‘Security’, check the option that says ‘Block third-party and advertising cookies’
3. Click ‘Save’

How to check cookies are enabled for Macs
Microsoft Internet Explorer 5.0 on OSX
1. Click on ‘Tools’ at the top of your browser window and select ‘Internet options’, then click on the ‘Privacy’ tab
2. Ensure that your Privacy level is set to Medium or below, which will enable cookies in your browser
3. Settings above Medium will disable cookies

Safari on OSX
1. Click on ‘Safari’ at the top of your browser window and select the ‘Preferences’ option
2. Click on ‘Security’ then ‘Accept cookies’
3. Select the ‘Only from site you navigate to’

Mozilla and Netscape on OSX
1. Click on ‘Mozilla’ or ‘Netscape’ at the top of your browser window and select the ‘Preferences’ option
2. Scroll down until you see cookies under ‘Privacy & Security’
3. Select ‘Enable cookies for the originating web site only’

Opera
1. Click on ‘Menu’ at the top of your browser window and select ‘Settings’
2. Then select ‘Preferences’, select the ‘Advanced’ tab
3. Then select ‘Accept cookies’ option

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

CONTACT US
Questions, comments and requests regarding this Privacy & Cookie Policy can be emailed to contact@liquid.auto.