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PRIVACY POLICY

Bethesda Car Detailing

Welcome to Bethesda Car Detailing’s privacy policy.

Bethesda Car Detailing respects your privacy and is committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format, so you can click through to the specific areas set out below.  Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

TABLE OF CONTENTS

  • Section I: Important Information & Who We Are

  • Section II: The Data We Collect About You

  • Section III: How Your Personal Dara is Collected

  • Section IV: How We Use Your Personal Data

  • Section V: Disclosures of Your Personal Data

  • Section VI: International Transfers

  • Section VII: Data Security

  • Section VIII: Data Retention

  • Section IX: Your Legal Rights

  • Section X: Glossary

SECTION I: IMPORTANT INFORMATION & WHO WE ARE

A. Purpose of this Privacy Policy.  This privacy policy aims to give you information on how We collect and process your personal data through your use of this website, including any data you may provide through this website when you purchase our products or services.  It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This privacy policy supplements other notices and privacy policies and is not intended to override them.

B. Controller. Bethesda Car Detailing is the controller and responsible for your personal data (referred to as “Bethesda Car Detailing,”, “we”, “us” or “our” in this privacy policy).

C. Contact Details.  If you have any questions about this privacy policy or our privacy practices, please contact our DPO/data privacy manager using the information below:

Bethesda Car Detailing

Support@KexelBRAND.com

101 N Haven Street

Suite 301

Baltimore, MD 21224

 

It is a breach of Our Terms of Use to use Our Website if you are a European Union resident or business and you shall cease any and all such further use immediately.  However, in the event that you are an EU resident or business and have nevertheless used Our Website or have purchased Our services, You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervising authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

D. Changes to the Privacy Policy and Your Duty to Inform Us of Changes.  We keep our privacy policy under regular review.  This version was last updated on November 27th, 2019.  

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us by sending us an email at Support@KexelBRAND.com.

E. Third Party Links.  This website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

SECTION II: THE DATA WE COLLECT ABOUT YOU

A. Personal Data.  Personal data, or personal information, means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

     (i) Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.

     (ii)Contact Data includes billing address, delivery address, email address and telephone numbers.

     (iii) Financial Data includes bank account and payment card details.

     (iv) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

     (v) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

     (vi) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

     (vii) Usage Data includes information about how you use our website, products and services.

     (viii) Marketing and Communications Data includes your preferences in receiving marketing from Us and our third parties and Your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect and Special Categories of Personal Data about you.  This includes information such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.  Nor do we collect any information about criminal convictions and offenses.

B. Failure to Provide Personal Data.  Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.  In this case, we may have to cancel a product or service you have with us. However, we will notify you if this is the case at the time.

SECTION III: HOW YOUR PERSONAL DATA IS COLLECTED

Data Collection Methods.  We use different methods to collect data from and about you, including through:

Direct interactions.  You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:

     (i) Apply for our products or services;

     (ii) Create an account on our website;

     (iii) Subscribe to our service or publications;

     (iv) Request marketing to be sent to you;

     (v) Enter a competition, promotion or survey; or

     (vi) Give us feedback or contact us.

  • Automated technologies or interactions.  As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.  We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

SECTION IV: HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with you, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.  You have the right to withdraw consent to marketing at any time by contacting us.

A. Purposes for which We will Use Your Personal Data.  We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set forth below.

 

Purpose/Activity:

To register you as a new customer/subscriber

Type of data:

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest:

Performance of a contract with you

Purpose/Activity:

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

Type of Data:

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity:

To manage our relationship with you, which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of Data:

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products or services)

 

Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):

Type of Data:

(a) Identity

(b) Contact

(c) Technical

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

Purpose/Activity:

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of Data:

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f)Technical

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of Data:

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

Purpose/Activity:

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

B. Marketing.  We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

C. Promotional Offers from Us.  We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which products, services and offers may be relevant for you (i.e. marketing).

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

D. Third-Party Marketing.  We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

E. Opting Out.  You can ask us or third parties to stop sending you marketing messages at any time by sending us an email at Support@KexelBRAND.com

When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, experience or other transactions.

F. Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

G. Change of Purpose.  We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please know that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

SECTION V: DISCLOSURES OF YOUR PERSONAL DATA

A. Permitted Disclosures.  We may share your personal data with the parties set forth below for the purposes set out in the table in Section IV(A) of this Privacy Policy.  Permissible parties include:

     (i) Internal Third Parties as set out in the Glossary.

     (ii) External Third Parties as set out in the Glossary.

     (iii)Specific Third Parties such as:

          (a) Gmail by Google

        

     (iv) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

B. Security of Your Personal Data.  We will require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

SECTION VI: INTERNATIONAL TRANSFERS 

In the event that we use service providers, vendors or work with other third parties located outside of the United States to provide you services hereunder, we will ensure that appropriate safeguards are put into place to appropriately protect your data in compliance with this Privacy Policy.

SECTION VII: DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

SECTION VIII: DATA RETENTION

A. In General.  We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

B. How We Determine the Data Retention Periods.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

C. Our Retention Periods in Detail. All data will be kept while You remain an active subscriber with Us and for a period of at least six (6) years thereafter.

D. Legal Requirements.  By law we have to keep basic information about our customers, including Contact, Identity, Financial and Transaction Data, for six (6) years after they cease being customers for tax and liability purposes.

E. Miscellaneous.  In some circumstances you can ask us to delete your personal data.  See Section IX below for further information. Additionally, in some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

SECTION IX: YOUR LEGAL RIGHTS

A. Rights of Data Subjects (You).  Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

     (i) Request access to your personal data.

     (ii) Request correction of your personal data.

     (iii) Request erasure of your personal data.

     (iv) Object to the processing of your personal data.

     (v) Request restriction of processing your personal data.

     (vi) Request transfer of your personal data.

     (vii) Withdraw Consent.

If you wish to exercise any of the rights set forth above, please contact us by email at Support@KexelBRAND.com

B. No Fee Typically Required.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights); provided, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

C. What We May Need from You.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

D. Time Limit to Respond.  We try to respond to all legitimate requests within one (1) month.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

SECTION X: GLOSSARY

A. LAWFUL BASIS.

     (i) Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

     (ii) Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

     (iii) Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

B. THIRD PARTIES.

     (i) Internal Third Parties:  We do not have any at this time.

     (ii) External Third Parties: We do not have any at this time.

C. YOUR LEGAL RIGHTS.  You have the right to:

     (i) Request access to your personal data (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

     (ii) Request correction of your personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

     (iii) Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

     (iv) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

     (v) Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios:

          (a) If you want us to establish the data’s accuracy.

          (b) Where our use of the data is unlawful, but you do not want us to erase it.

          (c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

          (d) You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

     

      (vi) Request a transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

     (vii) Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.