The data are collected by Adstrategy Global, Lda., a private limited company registered at the Commercial Registry of
Lisbon under NIPC 513241558, headquartered at R. Cidade de Bolama 38J esc. A,B,C,D, 1800-079 Lisbon, hereinafter
Adstrategy, subcontractor for the purposes of applying the General Data Protection Regulation, which collects them
on behalf of Driving Down Ltd.
Driving Down Ltd sees data privacy as a fundamental component of its business.
Driving Down Ltd processes personal data in accordance with applicable data protection
legislation, including the UK GDPR and, where applicable, Regulation (EU) 2016/679 (GDPR). Personal data may be
processed within the European Economic Area (EEA) and the United Kingdom where necessary for the operation of this
service. Where personal data is transferred from the EEA to the United Kingdom, such transfers may rely on the
applicable European Commission adequacy decision for the United Kingdom.
This platform is guided by the rules of the General Data Protection Regulation (Regulation (EU) 2016/679), as well
as any other applicable data protection legislation.
The privacy statement is the responsibility of Driving Down Ltd. The Data Protection
Officer (DPO) ensures compliance with the applicable regulation and is involved in all matters related to the
protection of personal data. Their identification and method of contact are indicated at the end of this document.
Driving Down Ltd is considered responsible for data processing for the purposes of
the GDPR and will determine the purpose and means of processing personal data submitted and collected online.
Principles
Our data protection policy ensures that the data is:
Subject to lawful, fair and transparent treatment in relation to the data subject ("lawfulness, fairness and transparency");
Collected for specific, explicit and legitimate purposes and cannot be further processed in a way incompatible with those purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and updated whenever necessary, with appropriate measures taken so that inaccurate data, taking into account
the purposes for which they are processed, are erased or rectified without delay;
Kept in a way that allows data subjects to be identified only for as long as necessary for the purposes for which they are processed;
Processed in a way that guarantees their security, including protection against unauthorized or unlawful processing
and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
Collection of personal data
In order to improve your browsing experience and provide the services you request, we may need to collect certain information. We make sure you know how the data entrusted to us is processed.
Depending on the version of the form, the information you provide and the options selected, we may collect the following information:
Cookies and technical information
Our website uses cookies or similar technologies to ensure the best user experience and to analyze trends, track the
movement of users within the website and collect demographic information about our user base as a whole. Our cookies
may record information such as Internet Protocol (IP) address, browser type, Internet Service Provider (ISP),
referring / exit pages, files accessed on our website (for example HTML pages), operating system, date and time, for
the purpose of analyzing trends on the site.
Retention period
Adstrategy will keep your data for 6 months and Driving Down Ltd is committed to
delete it within a maximum period of 24 months.
Where a UK VAT registration number is provided, the VAT number and the registered company name verified either
directly through HMRC or through Avatcado may be retained as part of the business enquiry record for the same
applicable retention period described above. Information returned by the verification service that is not required
for the enquiry will not be retained by us solely for the purpose of the VAT verification.
Where Avatcado is used, Avatcado states that it logs API usage information, including the VAT number queried,
endpoint called, API-key identifier, response status and timestamp, and retains validation history and API usage data
for as long as the relevant Avatcado account remains active. Avatcado's own retention practices are governed by its
privacy policy.
Minority
By accepting this privacy policy you guarantee that you are 16 years old or more.
Use of personal data
Driving Down Ltd will use the information you provide to manage your enquiry and,
where applicable and lawfully permitted, to contact you about the goods and / or services it sells. Access to
personal data is strictly limited to authorized personnel of those responsible for processing personal data and to
service providers or subcontractors that require access for the purposes described in this policy.
Verification of UK VAT registration details
Where the relevant version of our enquiry form requests a UK VAT registration number and you provide one, we may
verify that number using the HM Revenue & Customs (HMRC) Check a UK VAT Number service. Depending on the version
of the Service being used, the verification may be performed either directly with HMRC or through the third-party
VAT validation service Avatcado.
Avatcado is a VAT and GST validation service operated by De Jongh Software Development (KVK 84251352), established
in the Netherlands. For UK VAT-number checks, Avatcado submits the VAT number to HMRC for validation and returns the
resulting validation status and available company details to our server.
The purpose of the check is to confirm that the VAT number is registered, verify the identity of the associated
business and support our business due-diligence process, including identifying inaccurate or fraudulent business
information.
HMRC may return information associated with the VAT registration, including the registered business name and
registered address. For the purposes of this enquiry form, we use the registered business name to verify and
automatically complete the Company Name field.
Where Avatcado is used, the UK VAT registration number is transmitted securely from our server to Avatcado and then
to HMRC. Avatcado states that it logs API usage information including the VAT number queried, the endpoint called,
the API-key identifier, response status and timestamp. Avatcado processes this information in accordance with its
own privacy policy, available at
https://www.avatcado.com/privacy.
Other information submitted through this enquiry form, such as your name, email address, telephone number, postal
code or uploaded fuel-card invoice, is not sent to HMRC or Avatcado as part of the VAT registration lookup.
You are not required to provide HMRC or Avatcado sign-in credentials and we do not request, collect or store your
HMRC or Avatcado username or password for this verification.
The legal basis for this verification is our legitimate interest, and that of
Driving Down Ltd, in verifying the identity and registration details of prospective
business customers, carrying out appropriate business due diligence and preventing inaccurate or fraudulent business
enquiries.
Sharing of personal data and international transfers
Personal data may be shared with service providers and other recipients where this is necessary to operate the
service, process your enquiry, provide the requested services, comply with legal obligations or protect legitimate
business interests.
Where you provide a UK VAT registration number, that VAT number may be transmitted either directly to HM Revenue
& Customs (HMRC) in the United Kingdom or first to Avatcado, operated by De Jongh Software Development in the
Netherlands, which submits UK VAT numbers to HMRC for validation. This processing is carried out for business
verification and due-diligence purposes.
Avatcado processes API and validation information in accordance with its own privacy policy. HMRC is a UK public
authority and processes information in accordance with its applicable legal and data-protection obligations.
Personal data may therefore be processed within the European Economic Area (EEA) and the United Kingdom. Where the
GDPR applies to a transfer from the EEA to the United Kingdom, the transfer may rely on the applicable European
Commission adequacy decision for the United Kingdom.
Where personal data is transferred to another country outside the EEA or the United Kingdom and no applicable
adequacy decision exists, appropriate safeguards will be implemented as required by applicable data-protection legislation.
In certain circumstances, Driving Down Ltd and Adstrategy may also disclose
information where required by law, regulation, a competent supervisory authority or another legally authorised public authority.
Processing security
We will process personal data securely, applying and maintaining appropriate technical and organizational measures to
protect personal data against accidental or unlawful destruction, alteration, disclosure or unauthorized access,
including where processing involves transmission of data over a network.
Access and rectification or deletion of personal data
As data subjects, users have the right to request access to personal data concerning them, request its rectification
or deletion, restrict processing, object to processing where applicable, and request data portability where applicable.
You can also ask for clarification from the Data Protection Officer or file a complaint with the competent supervisory
authority whenever you believe that your rights are being violated.
Marketing emails
Where required, marketing communications will only be sent where an appropriate lawful basis exists. At any time the
user can withdraw consent or unsubscribe through the link provided for that purpose in each marketing email sent.
Responsibility
Driving Down Ltd is responsible for, and will be able to demonstrate, compliance
with applicable data protection legislation.
Changes to this policy
This policy may be updated from time to time, for example due to changes to the relevant legislation or to the way
services are provided. Where required by applicable law, material changes will be communicated appropriately.
Use of IP Address and Location
Our website uses the user's IP address and approximate geographic location to optimize the browsing experience.
Specifically, this information is used solely to automatically adjust the country flag and phone prefix displayed in
the contact form. This processing is based on our legitimate interest in facilitating form completion and improving
the site's usability. No precise location data is collected for this purpose.
Contacts
________________________________________
RESPONSIBLE FOR TREATMENT
Legal name: Driving Down Ltd
Address: Priestley House, 170 Elland Road, Leeds, LS11 8BU
Phone: 0113 518 3 518
Email: hello@drivingdown.co.uk
Client website: https://drivingdown.co.uk/
SUBCONTRACTING PARTY
Adstrategy Global
Address: R. Cidade de Bolama 38J esc. A,B,C,D, 1800-079 Lisbon
Email: comercial@adstrategyglobal.com
SUBCONTRACTOR'S DATA PROTECTION OFFICER
Adstrategy Global
Address: R. Cidade de Bolama 38J esc. A,B,C,D, 1800-079 Lisbon
Tel: 211962269
Email: dpo@adstrategyglobal.com