Privacy Policy

TestBuddy– Privacy Notice  

We at TestBuddy understand that your privacy is important and that you care about how your data is used and shared online. We respect and value the privacy of our clients and everyone else who visits this website, testbuddy.app (“our Site”) and will only collect and use personal data in ways that are described here and in a manner that is consistent with our obligations and your rights under the law.  

The procedures and principles set out in this Notice will always be followed by us as a company, our employees, sub-contractors or other parties working on our behalf.  

Please read this Privacy Notice carefully and ensure that you understand it. You are deemed to have accepted our Privacy Notice when you first use our Site. If you do not accept and agree with this Privacy Notice, you must stop using our Site immediately.  

I. Definitions and Interpretation  

In this Notice, the following terms have the following meanings:  

“Client” means any individual, firm or corporate body to which we provide our services;  

“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 11 below;  

“Data Protection Laws” means the General Data Protection Regulation 2016/679 (“GDPR”) and Data Protection Act 2018;  

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us by becoming a client of ours or by visiting our Site. This definition shall, where applicable, incorporate the definitions provided in the applicable Data Protection Laws; and  

“We/Us/Our” means New Driver Programme, a company registered in England and Wales under number 09981078, whose registered office is at 82A, James Carter Road, Mildenhall, Suffolk, IP28 7DE, United Kingdom.  

II. What Does This Notice Cover?  

1. This Privacy Notice applies to our use of personal data collected when you become a Client of ours, when you enquire about our services or when you visit our Site; you may choose to upload further personally identifying data through your use of the Site in comments and to message; however, this shall be at your discretion.  
2. Our Site may contain links to other websites, including social media links. Please note that we have no control over how your data is collected, stored, or used by other websites, and we advise you to check the privacy policies of any such websites before providing any data to them.  

III. Your Rights  

As a data subject, you have the following rights under the applicable Data Protection Laws, which this Notice and our use of personal data have been designed to uphold:  

The right to be informed about our collection and use of personal data;  

1. The right of access to the personal data we hold about you (see section 10);  
2. The right to rectification if any personal data we hold about you is inaccurate or incomplete (please get in touch with us using the details in section 12);  
3. The right to be forgotten – i.e., the right to ask us to delete any personal data we hold about you (we only hold your data for a limited time, as explained in section 5, but if you would like us to delete it sooner, please get in touch with us using the details in section 12);  
4. The right to restrict (i.e., prevent) the processing of your data;  
5. The right to data portability (obtaining a copy of your data to re-use with another service or organisation);  
6. The right to object to us using your data for particular purposes; and  
7. Rights concerning automated decision-making and profiling.  

If you have any cause for complaint about our use of your data, please contact us using the details provided in section 12, and we will do our best to solve the problem for you. If we are unable to help, you also have the right to complain to the UK’s supervisory authority, the Information Commissioner’s Office.  

Please contact the Information Commissioner’s Office or your local Citizens’ Advice Bureau for further information about your rights.  

IV. What Data Do We Collect, and How Do We Use Your Data?  

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

1. Identity Data includes first name, last name, title, username or similar identifier.  
2. Contact Data includes billing address, site address, email address, and telephone numbers.  
3. Financial Data includes bank account and payment card details.  
4. Transaction Data includes details about payments to and from you and other services you purchased from us.  
5. 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 this Site.  
6. Profile Data includes your username and password, interests, preferences, feedback and survey responses.  
7. Usage Data includes information about how you use our Site and services, including but not limited to comments and messages on the Site.  
8. Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.  

All personal data is processed and stored securely for no longer than is necessary or statutorily required in light of the reason(s) for which it was first collected.

We will always comply with our obligations and safeguard your rights under the applicable Data Protection Laws. For more details on security, see section 5 below.  

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To commence working with you as a new or returning client	Identity   Contact	Performance of a contract with you
To deliver our services to you, including:  (a) Managing payments  (b) Collecting and recovering money owed to us	Identity  Contact  Financial  Transaction  Marketing and Communications	(a) Performance of a contract with you  (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, which will include:  (a) Notifying you about changes to our terms or website policies  (b) Asking you to leave a review or take a survey	Identity  Contact  Profile  Marketing and Communications	(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 clients use our services)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity   Contact Technical	(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 reorganisation or group restructuring exercise)  (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity  Contact  Profile  Usage Marketing and Communications  Technical	Necessary for our legitimate interests (to study how clients use our services, to develop our services, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, services, marketing, client relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of clients for our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	Identity  Contact  Technical  Usage  Profile  Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

1. With your permission and/or were permitted by law, we may also use your data for marketing purposes, including emailing you with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the applicable Data Protection Laws and the Privacy and Electronic Communications (EC Directive) Regulations 2003.  
2. Third parties whose content appears on our Site may use third-party Cookies, as detailed below in section 11. Please refer to section 11 for more information on controlling Cookies. Please note that we do not control the activities of such third parties nor the data they collect and use, and we advise you to check the privacy policies of any such third parties.  
3. You have the right to withdraw your consent to us using your data at any time and request that we delete it. Unless we have reasonable grounds to refuse to delete it (where this is permitted under the applicable Data Protection Laws), we will do so without delay and within no longer than one month of receiving your request.  
4. We only keep your data for as long as is necessary for light of the reason(s) for which it was first collected. 

V. How and Where Do We Store Your Data?

1. We only keep your Personal Data for as long as we need to in order to use it as described above in section 4, and/or for as long as we have your permission to keep it.
2. We will only store your data in the UK, however, third party processors we use may store data elsewhere, as set out in section 6
3. Data security is very important to us and to protect your data, we have taken suitable measures to safeguard and secure data collected.

VI. Do We Share Your Data?

1. We may sometimes contract with other third parties to supply services to you on our behalf, such as sub-contractors, and in some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and following your rights, our obligations, and the obligations of the third party under the law.  
2. We may compile our site’s use statistics, including traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data or any anonymised data that can be combined with other data and used to identify you. Occasionally, we may share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.  
3. We may sometimes use third-party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the applicable Data Protection Laws.  
4. In certain circumstances, we may be legally required to share specific data held by us, which may include your personal data, for example, where we are involved in legal proceedings, complying with legal requirements, a court order, or a governmental authority.  

VII. What Happens If Our Business Changes Hands?

1. From time to time, we may expand or reduce our business, which may involve the sale and/or transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part. Under the terms of this Privacy Notice, the new owner or newly controlling party will be permitted to use that data only for the same purposes for which we originally collected it.  
2. If any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

VIII. How Can You Control Your Data?

1. In addition to your rights under the applicable Data Protection Laws, set out in section 3, when you submit personal data to us via email or our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).  
2. You may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may prevent you from receiving unsolicited marketing. Please note, however, that these services will ensure you receive marketing communications you have consented to receive. 

IX. Your Right to Withhold Information

1. You may access certain areas of our Site without providing any data. However, to use all features and functions available on our Site, you may be required to submit or allow for collecting specific data.  
2. You may restrict our use of Cookies. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether to disable all cookies or only third-party Cookies. Most internet browsers accept Cookies by default, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. 

X. How Can You Access Your Data?

1. You have the right to request a copy of any of your personal data held by us (where such data is held). Please contact us for more details using the contact details below in section 12.  

XI. Our Use of Cookies

1. All Cookies used by and on our Site are used following current Cookie law.  
2. We may place and access the following first-party and third-party Cookies on your computer or device, to facilitate and improve your experience of our Site and to provide and improve our services
3. First-party Cookies are those placed directly by us and are used only by us. Third-party Cookies are those placed by websites, services, and/or parties other than us. These Cookies are not integral to the functioning of our Site, and your use and experience of our Site will not be impaired by refusing consent to them.  
4. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to placing Cookies, you are enabling us to provide you with the best possible experience and service. If you wish, you may deny consent to placing Cookies; however, certain features of our Site may not function fully or as intended.  
5. Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are also shown above. Your consent will not be sought to place these Cookies, but it is still essential that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed in clause 10.2, but please be aware that our Site may not work correctly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.  
6. Our Site uses Google Analytics. Website analytics refers to tools used to collect and analyse anonymous usage information, enabling us to understand better how our Site is used. This, in turn, enables us to improve our Site and its services. You do not have to allow us to use these Cookies; however, whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better and more helpful experience for you. Google’s privacy policy is available at: google.com/policies/privacy  
7. You can delete Cookies on your computer or device at any time; however, you may lose any information that enables you to access our Site more quickly and efficiently.  
8. It is recommended that you keep your internet browser and operating system up-to-date and consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you need clarification on adjusting your privacy settings. 

XII. Contacting Us

If you have any questions about our Site or this Privacy Notice, please contact us by email at support@newdriverprogramme.com. Please ensure that your query is clear, mainly if it is a request for information about the data we hold about you (as under section 10, above).  

XIII. Changes to Our Privacy Notice

We may change this Privacy Notice occasionally (for example, if the law changes). Any changes will be immediately posted on our Site, and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our Site following the alterations. Please check this page regularly to keep up-to-date.