Introduction

Client ETA is committed to protecting your privacy and handling personal information responsibly.

Client ETA is operated by HHW Digital Solutions Ltd.

This Privacy Policy explains how Client ETA collects, uses, stores, shares and protects personal information when you access or use our website, application and associated services.

Some personal information may be provided directly by you, while other information may be received through the use of permitted Client ETA features.

Information We Collect

Depending on how you interact with Client ETA, we may collect and process information including:

• Full name.
• Email address.
• Phone number provided for membership or verification purposes.
• Advert or website links submitted during verification.
• Membership and application information.
• Device and browser information.
• Device or installation identifiers.
• IP address and technical information.
• Security and access information.
• Information submitted through permitted platform features.
• Arrival Update information.
• Customer support communications.
• Dispute, correction or privacy request information.
• Payment and membership status information.

The information collected will depend on the features and services being used.

How We Use Information

Client ETA may use personal information to:

• Verify membership applications.
• Manage memberships.
• Provide access to Client ETA.
• Provide and support Client ETA platform functionality and services.
• Maintain platform security.
• Prevent fraud, misuse and unauthorised access.
• Manage registered devices.
• Provide Arrival Updates.
• Provide customer support.
• Handle privacy, correction and dispute requests.
• Administer payments and membership status.
• Maintain appropriate records.
• Improve platform functionality and reliability.
• Protect the security and integrity of Client ETA.
• Comply with legal and regulatory obligations.
• Establish, exercise or defend legal claims where necessary.

Lawful Basis for Processing

Client ETA only processes personal information where permitted by applicable data protection law.

Depending on the circumstances, this may include where processing is necessary to:

• Provide our services.
• Manage a membership or application.
• Meet our legal obligations.
• Protect our legitimate business interests.
• Maintain platform security and prevent misuse.
• Protect the rights and interests of individuals.
• Respond to legal claims or lawful requests.
• Provide an optional feature where consent has been given.

Where consent is relied upon, it may be withdrawn at any time.

Withdrawing consent does not affect processing that was lawful before consent was withdrawn.

Arrival Updates and Location Information

Arrival Updates are optional.

Where a user chooses to activate an Arrival Update, Client ETA may temporarily process location-related information necessary to provide the feature.

This may include:

• Device location information.
• Generalised location information.
• Estimated arrival time.
• Arrival progress.
• Relevant time information.

Client ETA is designed to provide generalised area and arrival-progress information rather than an exact private home or work address.

Location information used for an Arrival Update is intended to support the temporary operation of that feature.

Users may stop an active Arrival Update using the controls provided.

Client ETA does not intend to create a permanent history of a user's complete travel route through the Arrival Update feature.

Limited technical information may be retained where reasonably necessary for security, troubleshooting, legal compliance or dispute handling.

Information Submitted Through Client ETA

Personal information may be processed where it is submitted through permitted Client ETA features or otherwise provided in connection with the use of our services.

Client ETA aims to process only information that is relevant and reasonably necessary for the purposes for which it is used.

If you believe Client ETA holds or processes personal information relating to you and you would like to review, correct, restrict or request removal of that information, please contact us through our official support channels.

Information Sharing

Client ETA does not sell personal information.

Personal information may be shared with authorised service providers where reasonably necessary to operate and support Client ETA.

These may include:

• Hosting and infrastructure providers.
• Email providers.
• Payment processors.
• Security and fraud-prevention providers.
• Mapping or location-service providers.
• Technical service providers.
• Professional advisers.

Service providers are expected to process personal information only for authorised purposes and in accordance with applicable legal and contractual requirements.

Personal information may also be disclosed:

• Where required by law.
• In response to a valid court order.
• In response to a lawful regulatory request.
• In response to a lawful law enforcement request.
• Where necessary to establish, exercise or defend legal claims.
• Where reasonably necessary to investigate fraud or serious misuse.
• Where legally permitted and reasonably necessary to protect an individual from serious harm.

International Data Transfers

Some authorised service providers may process personal information outside the United Kingdom.

Where personal information is transferred internationally, Client ETA will use an appropriate lawful safeguard or transfer mechanism where required by applicable UK data protection law.

Data Retention

Client ETA retains personal information only for as long as reasonably necessary for the purpose for which it was collected or where another lawful reason for retention applies.

Retention periods may depend on:

• The type of information.
• Membership status.
• The purpose for which the information is used.
• Security requirements.
• Fraud prevention.
• Privacy or dispute requests.
• Legal claims.
• Legal or regulatory obligations.

Membership and verification information may be retained for the duration of membership and for an appropriate period afterwards where reasonably necessary.

Information submitted through Client ETA may be retained for as long as reasonably necessary for the operation, security and integrity of the service or where there is another lawful reason to retain it.

Arrival Update information is intended to be temporary and is not intended to create a permanent travel history.

Support, privacy and dispute communications may be retained for an appropriate period to respond to the matter and maintain necessary records.

Information that is no longer required will be deleted, anonymised or securely disposed of where appropriate.

Data Security

Client ETA uses reasonable technical and organisational measures designed to protect personal information against:

• Unauthorised access.
• Accidental loss.
• Unlawful disclosure.
• Alteration.
• Destruction.
• Misuse.

Security measures may include:

• Access controls.
• Device-related security measures.
• Restricted administrative access.
• Verification controls.
• Secure hosting.
• Technical monitoring.
• Data minimisation.

No internet-based service can guarantee absolute security.

Users are also responsible for maintaining the security of their own devices and access to Client ETA.

Your Data Protection Rights

Depending on the circumstances and applicable law, you may have the right to:

• Request access to personal information relating to you.
• Request correction of inaccurate information.
• Request deletion of personal information.
• Request restriction of certain processing.
• Object to certain processing.
• Request transfer of information where applicable.
• Withdraw consent where processing is based on consent.
• Raise a complaint regarding the handling of your personal information.

These rights are not absolute and may be subject to legal exceptions.

Client ETA may retain or continue processing information where there is a lawful reason to do so.

We may need to verify your identity before completing certain privacy requests.

Privacy Requests

If you believe Client ETA holds or processes personal information relating to you and you would like to review, correct, restrict or request removal of that information, please contact us.

We will consider requests in accordance with applicable data protection law.

A request for deletion or removal does not automatically require information to be deleted where Client ETA has a lawful reason or legal obligation to retain it.

Cookies and Similar Technologies

Client ETA may use cookies and similar technologies to support:

• Essential platform functionality.
• Security.
• User sessions.
• Appropriate preferences.
• Prevention of misuse.
• Technical performance.

Where non-essential cookies or analytics require consent under applicable law, consent will be requested before those technologies are used.

Further information may be provided through a separate Cookie Policy or cookie-management tool.

Automated Processing

Client ETA may use automated technical processes to operate platform functionality and maintain security.

Client ETA does not currently use solely automated decision-making that produces legal or similarly significant effects on individuals without appropriate safeguards.

Children's Privacy

Client ETA membership is restricted to individuals aged 18 or over.

Client ETA is not intended for use by children.

Legal and Regulatory Disclosures

Client ETA may preserve or disclose personal information where required or permitted by law.

This may include circumstances involving:

• Court orders.
• Lawful law enforcement requests.
• Regulatory requirements.
• Legal proceedings.
• Fraud investigations.
• Serious safeguarding matters.
• Establishing, exercising or defending legal claims.

Any disclosure will be considered in accordance with applicable data protection law.

Changes to This Privacy Policy

Client ETA may update this Privacy Policy from time to time.

Changes may be made to reflect:

• Changes to Client ETA services.
• New functionality.
• Changes to service providers.
• Changes to legal or regulatory requirements.

The latest version of this Privacy Policy will be made available through Client ETA.

Where appropriate, significant changes may also be communicated to users.

Complaints

If you have concerns about how Client ETA handles your personal information, please contact us so that we can review the matter.

You also have the right to raise a complaint with the Information Commissioner's Office (ICO) if you believe your personal information has been handled contrary to applicable data protection law.

Contact Us

For privacy-related enquiries, requests, corrections or complaints, please contact:

support@clienteta.app

HHW Digital Solutions Ltd

Data Controller: HHW Digital Solutions Ltd

ICO Registration Number: ZC224600