1.1 For the purpose of the Data Protection Act (“DPA”) and, from 25th May 2018, the General Data Protection Regulation (“GDPR”) (together, the “Data Protection Laws”), the data controller is TT2 Limited (CRN: 06346957) whose registered address is Tyne Tunnels, Wallsend, Tyne and Wear, NE28 0PD (“we”, “our”, “us”). The website https://www.tt2.co.uk/ (“Website”) and our mobile application Tyne Tunnels TT2 (“App”) is owned and operated by TT2 Limited.
1.2 We are committed to protecting and respecting your privacy. This statement relates to the personal information that we obtain from you and we will only request personal information that is necessary to enable us to provide our services (“Services”). Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By requesting a user account (“Account”) and using the App, you are accepting and consenting to the practices described in this statement.
1.3 Personal information we collect from you.
1.3.1 The type of information we will collect about you includes:-
(a) your name and address;
(b) your phone number and e-mail address;
(c) information included in your new Account registration form;
(d) information you provide when your register to use the App, download or register the App, or make an in-App purchase.
(e) information you complete (if any) in relation to our client surveys;
(f) your current location disclosed by GPS technology. This information will be collected through our App. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. By using the App, device information may also be obtained. You can withdraw your consent at any time by disabling the location services associated with the App in your settings;
(g) visual information collected by our use of security cameras (as situated on either side of and at various locations within the Tyne Tunnels) and the ANPR system; and
(h) audio information collected by our use of recording equipment on telephone and intercom systems. We may use the recordings to check any instructions given to us, for training purposes, for crime prevention, for legal proceedings and/or to improve the quality of our customer service. You may be informed at the start of our conversations regarding this recording and if you do not wish to proceed, we will be happy to contact you in another manner, such as by e-mail.
1.3.2 The information you provide to us or that we collect from you may be processed for the following reasons:-
(a) the maintenance of necessary records;
(b) to carry out research (which may include surveys if you have expressly consented to this). We will not, however, undertake any automated profiling activities using your personal information without your express prior consent;
(c) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. This may include the provision of a permit tag to you (“Tag”) and/or our use of the Automatic Number Plate Recognition system (“ANPR system”) to you if you wish to use the Tyne Tunnel on a pre-paid basis;
(d) to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about, unless you opt-out of this by clicking the appropriate link in our communications or contacting us through clause 1.3.9 below;
(e) to provide you, or permit selected third parties to provide you, with information about goods or services (or other marketing activities) we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those that we have already provided to you (as set out in clause 1.3.1(d) above). If you are a new customer, and where we permit selected third parties to use your personal information, we (or they) will contact you by electronic means only if you have expressly consented to this by ticking the relevant box situated on the form on which we collect your data (for example, your new Account registration form). You can opt out of this contact at any time by clicking the appropriate link in the communications, contacting the third party or contacting us through clause 1.3.9 below;
(f) to notify you about changes to our Services;
(g) to ensure that content from our Website is presented in the most effective manner for you and for your computer;
(h) to administer our Website and your Account for internal operations, including troubleshooting, data analysis, testing, research, statistical and (if relevant) survey purposes;
(i) to allow you to participate in interactive features of our Services (if any), when you choose to do so;
(j) as part of our efforts to keep our Website and your Account safe and secure; and
(k) to measure or understand the effectiveness of advertising we serve to you and others (if any), and to deliver relevant advertising to you (if any).
(l) to administer our unpaid toll charge scheme, revenue protection, collection of unpaid tolls and charges, fraud prevention and the prosecution of byelaw offences.
1.3.3 With regard to each of your visits to our Website, we may automatically collect and the following information about your visit:-
(a) the internet domain and IP address from where you access our Website;
(b) the type of browser software and operating system used to access our Website;
(c) the date and time you access our Website;
(d) the pages you enter, visit and exit our Website from; and
(e) if you linked to our Website from another website, the address of that website.
1.3.4 We may also collect, use and share aggregated data such as statistical or demographical data for any purpose (“Aggregated Data”). 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 details of your use of our App or visits to our Website including, but not limited to, traffic data and other communication data to calculate the percentage of users accessing a specific App 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 statement.
1.3.5 If you proceed to make a payment you will be directed to a website operated by Sage Group (“Sage”). Sage will require personal information from you in order to process your payment. You should read Sage’s privacy policy and terms and conditions for details of how this information will be used. Sage will inform us of the amount and date of any payment you make only and we will handle this information in accordance with this privacy statement. Please note that we will not ask for or have access to your credit or debit card details at any time and we are not responsible for the use or retention of any information that you provide to Sage.
1.3.6 We will never collect sensitive or “special categories” of personal information (as defined in the Data Protection Laws) about you without your prior express consent.
1.3.7 The legal bases by which we process your personal information include:
(a) To perform our contract with you.
(b) To comply with our legal obligations
(c) To pursue legitimate business interests of our own related to providing our services to you and operating the Website, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests.
(d) For the establishment, exercise or defence of legal claims, where necessary.
(e) Where you have expressly given your consent to us to process your personal data.
1.3.8 Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
1.3.9 In those limited circumstances where you have expressly given your consent to us to process your personal data, you are free to revoke your consent at any time; however, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned in clause 1.3.6 above.
1.3.10 If you change your mind about receiving marketing information from us in the future, please contact us in writing addressed to TT2 Limited, Administrative Building, Wallsend, Tyne & Wear, NE28 0PD, through our Customer Services page.
1.4 Storage of your personal information and permitted disclosures.
1.4.1 Any information that we collect about you is stored electronically on our internal database. It may also be printed and stored in our filing system. We will store this information for no longer than is necessary for the purposes set out in this statement, in accordance with the Data Protection Laws.
1.4.2 We will keep your personal information confidential except to the extent that:
(a) we may disclose your personal data to third parties if we are compelled to disclose it by law or requests are made by the police or other law enforcement agencies or to comply with an instruction of a regulatory body of competent jurisdiction. This may include the Driver and Vehicle Licensing Agency (DVLA), local authorities, insurance companies and/or other organisations for the administration, enforcement of the exempt permit scheme, motor offences and the prevention and detection of crime. We may disclose your personal data in order to enforce or apply our terms of use (see https://www.tt2.co.uk/help/terms-of-use/) or terms and conditions of supply (see https://www.tt2.co.uk/using-the-tunnels/) and other agreements.
We may also do so to protect the rights, property, or safety of TT2 Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud detection and protection, revenue protection and prosecution of byelaw offences.
(b) from time to time we may be called upon to demonstrate our maintenance of certain professional standards as set by appropriate authorities and/or to satisfy our auditors and/or to comply with regulations in relation to money laundering or other statutory requirements. If you do not consent to our production of your details for this purpose only as an exception to our duty of confidentiality, you can let us know by contacting through our Customer Services page;
(c) we are reasonably required to make a disclosure to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
(d) we are reasonably required to make a disclosure to business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
(e) we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
(f) if TT2 Limited or substantially all of its assets are acquired by or transferred to a third party, in which case personal information held by it will be one of the transferred assets.
1.4.3 We may also randomly select and monitor vehicles (subject to exemption) to identify possible fraudulent use of the exempt permit scheme. If you defraud or attempt to defraud that scheme, we may record your vehicle’s movement and may disclose relevant details to local authorities and / or law enforcement agencies, to assist in tracing evaders and those committing fraud.
1.4.4 If you believe that the information we hold about you is inaccurate or if you wish us to cease processing your data for any particular purpose or purposes, please contact us through our Customer Services page. The withdrawal of your consent at any time will not affect the lawfulness of any processing carried out before you withdraw your consent.
1.4.5 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have implemented appropriate organisational and technical measures to keep your personal information safe and secure. When you register for an Account with us, you will be required to adhere to the security provisions set out in our terms and conditions.
1.4.6 Your personal information is held securely on our (or our Internet service provider’s) secure servers within the European Economic Area (“the EEA”). We will not make any transfer of your personal information outside the EEA without your prior consent.
1.5 Your rights
1.5.1 Should you wish to obtain a copy of the personal information that we hold about you, transfer this information to another provider or ask us to delete this information, please contact us through our Customer Services page. As soon as we are satisfied as to your identity, we will either send to you a copy of all of the information that we hold concerning you, provide your information in electronic form for transfer or confirm that your information has been deleted (as applicable and subject to any legal obligations that we may have). If there is an associated administration fee chargeable, we will advise you of this at the time.
1.5.2 If you have a complaint regarding any breach of this privacy statement, please contact us through our Customer Services page. You can also make a complaint directly to the Information Commissioner’s Office, the UK supervisory authority for data protection issues, through the website https://ico.org.uk/concerns/
1.6 Cookies
1.6.1 When visiting our Website or App, we may from time to time use tracking technologies which record information about you automatically. This helps us to provide you with a good experience when you use the App or browse our Website and also allows us to improve the App and the Website. This can include using a “cookie” which would be stored on your browser – you will see a notification of this when you access the Website. If you do not want this to happen, you may disable the cookies by following the instructions provided by your browser but certain functionality of this site might be affected and you might not be able to access certain Website pages. This information does not identify you personally.
1.6.2 We currently use cookies on our Website and App, including but not limited to the following cookie:
Cookie: Google Analytics
Purpose: The provision of marketing analytics
More information: https://www.google.com/analytics/#?modal_active=none
1.7 Changes to our privacy statement
We keep our privacy statement under regular review. Any changes we make to our privacy statement in the future will be posted on this page and, where appropriate, either notified to you by e-mail or when you next start the App. Please check back frequently to see any updates or changes to our privacy statement.
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 our relationship with you.
1.8 Third party links
Our App and Website may, from time to time, contain links to and from other websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact information or location information. Please check these policies before your submit any personal data to these websites or use these services.
1.9 Contact
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to TT2 Limited, Administrative Building, Wallsend, Tyne & Wear, NE28 0PD