Camplify Privacy Policy

This privacy policy informs you about data processing at Camplify Co (UK) Ltd  ("Camplify" or "we"). This statement applies to all products and services (provided by Camplify, regardless of whether the  products or services are provided via our websites, mobile apps, social media or other channels.

This Privacy Policy explains:

• what personal data we collect;
• why we collect the data and what we do with it;
• about your rights in connection with our data protection processing;
• what technologies and data we use to personalise and tailor our services and content to provide our users with a safe, simple, seamless experience;
• which technologies and data we use for advertising purposes and which tracking technologies we use.

1. Responsible party under UK GDPR**. Camplify Co (UK) Ltd, London, Great Britain, support@camplify.co.uk “UK GDPR" means the Data Protection Act 2018, as well as the GDPR (General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016)   as it forms part of the law of England and Wales, Scotland and Northern Ireland.  

• provision, performance, personalisation and design of the Camplify platform for peer to peer rental of motorhomes, camper vans, caravans and other recreation vehicles (RVs) including related  insurance services;
• further development of our products and services;
• providing customer service including chatbots and receivables management;
• the provision of news, messages, newsletters and other direct communication, to the extent legally permissible or as required to provide you with contracted products and services;
• maintaining the security, operability and stability of our products and services, including defence against system attacks;
• non-promotional communication with users on technical, security and contract-related issues such as fraud warnings, account blocking or amendments to Camplify’s terms and conditions;
• the issue, redemption and delivery of gift and other vouchers;
• organising promotions and competitions, including deciding and announcing the winner and prize handover.

We also use your data for the purposes of product development, market research, optimisation of business processes, and for personalised advertising.

2.1 Profile and identity data. Profile data is personal and demographic information about you (known as personal master data) that you provide to us when you register. Profile data includes, first and last names, contact details (e.g. address, email address, telephone number) and profile pictures. Mandatory information always includes your name, email address and a password of your choice. Your email address and password are required to access our services.  Your date of birth and driving licence details may be required for the use of certain services. We also require additional information from owners, such as the advertised RV, bank details, tax information and, if applicable, company data and registration numbers. This also includes data that you provide voluntarily in your profile.

To verify your identity, it may be necessary to present an official identification document. We collect and process the information contained in this document in accordance with the applicable laws.  Your identification may be used to confirm your appropriately licensed to drive a hired RV and may be required for insurance purposes. Where information is mandatory, this will be set out on the Camplify Platform or Camplify App where information is collected. 

2.2 Listing & booking data. In order to arrange and process bookings, we process the information provided in the listing about the listed RV, including the photos provided, the available extras and any applicable additional information. For bookings, we process the following data:

• Booking number
• Booking details, including the RV booked, extras, insurance benefits, rental period
• Invoice address
• Booking-related notifications and communication
• Telephone number for support purposes
• Date of birth to verify your age for services eligibility and insurance purposes
• Payment method

2.3 Payments.  We may offer various payment options, such as payment in advance, payment by credit card and payment by PayPal. The specific payment methods available will be displayed at the time of booking. For payment processing, payment data may be transmitted to payment service providers, with whom we have data processing agreements. Payment service providers also process personal data on their own behalf. Further information can be found in the payment service providers' privacy policies:

• Airwallex (UK) Limited, Labs House, 15-19 Bloomsbury Way, London WC1A 2TH, United Kingdom. Privacy Policy of Airwallex
• Adyen N.V., Simon Carmiggeltstraat 6-50, 1011 DJ Amsterdam, the Netherlands. Privacy policy of Adyen
• Google Pay. Privacy policy of Google.
• PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg. Privacy policy of PayPal.

Credit card. If you pay with your credit card, your credit card provider will receive the information that you have placed an order with us. Your credit card provider may carry out a credit check. You can find more information about this on the website of your credit card provider.

Payment data includes:

• Preferred payment method
• Invoice addresses
• IBAN and BIC or account number and sort code
• Credit card details
• Identifiers such as a PayPal ID

2.4 Contact details. When you contact us, we collect your contact details to communicate with you, such as your name, postal address, telephone number, email address, details of your social network profiles (e.g. Facebook ID) and username.

2.5 Customer service & content in messages, user reviews and other usage data. When you communicate with our customer service staff we keep a copy of your messages and our response to you. We also process other content that you generate when using our products and services or that relates to your account (e.g. user reviews for publication on our platform) and content that you exchange with other users via our messaging tools, including to support the rental contracts entered into via the Camplify Platform. Where applicable, we will forward your messages to the relevant party, for example an insurance provider or another user who you have made a booking with.

2.6 Chatbot & live chat. In some of our services, it is possible to communicate with us via chatbot and live chat. A chatbot is a technical assistant that automatically answers questions on various topics. Use of the chatbot service is voluntary and does not require login or registration. If the chatbot is unable to answer your question, you can switch to the live chat if necessary and seek an answer from our customer service staff. It is not necessary to enter personal data to use our chat service. The answers and content of the chat service is generic, the chatbot is not intended to provide legally binding information specific to your circumstances. 

If you are not a registered user or are not logged in to any of our services when using the chat, your data from the chat will be deleted or anonymised 180 days after the chat has ended.

2.7 Social network data. We maintain profile pages in social networks and have integrated functions of social networks into our services, such as short message services (messenger), social plug-ins and social logins such as "Sign in with Facebook". If you contact us as a member of a social network via our profile page or use the social network functions integrated in our services, we may receive data from their operators that can be used to identify you. As a rule, this is the following data:

• Your public profile information (e.g. name, profile picture)
• Details of the device type used
• the account ID of your profile, e.g. the Facebook ID

These are privacy policies of the most common social network providers:

Facebook, Google, TikTok, Instagram, YouTube, Pinterest

2.8 Newsletter.  If you subscribe to our newsletter, we will use your data to send you the newsletter by email and, if you have also consented to this, to analyse how you use the newsletter and any content linked to it. We use your name to address you personally in the newsletter and to identify you if you wish to exercise your rights as a data subject, in respect of the newsletter. The following data is stored in respect of your subscription. 

• Place, date and time of registration
• IP address
• E-mail address
• Title, first name, surname, if applicable

You can unsubscribe from the newsletter at any time. You will find the unsubscribe link at the end of the newsletter. By unsubscribing, you revoke your consent and object to any further use of your data for the purpose of sending the newsletter.

2.9 Direct advertising. If you make use of our products and services, for example by listing, renting or booking a vehicle, we may use your e-mail address to send you direct advertising for similar goods or services that we provide.
If you have given your consent, we can send you direct advertising for other goods and services. You can withdraw your consent at any time by sending an email to support@camplify.co.uk or by clicking on the unsubscribe link in an advertising email.

2.10 Insurance benefits.  Owner members can join a fleet insurance policy held by Camplify (UK) for the duration of the rental.  Hirer members may have access to the travel insurance policies, provided by Camplify’s travel insurance partner. Depending on the insurance policy, we process the following data certain pre-contractual information (name, residential address, date of birth, age, driver’s licence details, e-mail address, telephone number, travel period, vehicle data such as chassis number and licence plate number, booking number) so that insurance services can be offered. Once the cover is issued, we process the data required in each case, such as the insurance number, booking number, booking status, so that insurance benefits can be provided by the respective partner. In doing so, we process data and pass on data to the insurer

• to check the authorisation to take out booking insurance based on the travel information;
• to enable the insurance partner to underwrite and administer the insurance (e.g. insurance claims and benefits);
• to fulfil and manage our contract with the insurance partner;
• to implement and enforce insurance conditions;
• to comply with legal obligations; and
• to fulfil official requirements.

Our insurance providers also process data on their own behalf on the basis of their own data protection provisions. Insofar as the partners' offers are integrated into our services, separate reference is made to data processing by partners before the start of data processing and your consent is obtained if necessary.

2.11 Debt collection. We reserve the right to send reminders for outstanding debt, including by using appropriate service providers. If outstanding debts are not paid despite repeated reminders, we may transmit the data necessary to engage a debt collection service provider for the purpose of collecting the debt. Alternatively, we can sell the debt to a debt collection service provider who can then collect the debt in its own name.

2.12 Business management and optimisation.  We may transmit and process your data for administrative and logistical processes and to optimise business processes within the "CHL Group" (see section 4) to make them more efficient, legally compliant and to comply with our contractual and legal obligations (e.g. commercial and tax reporting obligations). Many systems and technologies are shared within the CHL Group. This enables us to offer a more secure, standardised and personalised service using economies of scale. Accordingly, various companies within the CHL Group may have access to your data in order to fulfil the purposes set out in this Privacy Policy. Data processing for business management and business optimisation also includes the following purposes:

• Implementation and improvement of customer service.
• Prevention and investigation of criminal offences.
• Ensuring the security and operability of our IT systems.

2.13 Processing based on your consent. As part of the use of our products and services, we may ask for your consent to certain data processing. Consent is always for a specific purpose, voluntary and can be revoked at any time. We may request your consent for the following purposes:

• Newsletter
• Participation in surveys and market research studies.
• Recording of telephone conversations (customer service).
• Disclosure of your data to our partners for advertising purposes.

2.14 Vouchers. We use the data provided when purchasing vouchers to check and process the order and to send and redeem the voucher. This also includes logging and processing the data associated with the use of the voucher to prevent fraud. We may also store the following data for these purposes:

• Issue date, voucher value, voucher code.
• Name of the person entitled to the voucher (for personal vouchers).
• Time of voucher redemption.
• Name of the redeemer and the user account ID of the account used for the redemption.

2.15 Competitions & promotions. Your personal data will be processed for the purposes of running the competition or promotion, checking eligibility to participate and determining and notifying the winners. We may subsequently collect and process additional data, e.g. your address, for the purpose of sending prizes. In some cases, a telephone number must be provided if it is necessary to contact you at short notice in order to run the competition. 

Competitions or promotions may also be used for the purpose of obtaining contact details for direct advertising measures by us and/or one of our partners. If you have consented to receive advertising separately, you can revoke your consent at any time by sending an email to support@camplify.co.uk or by clicking on the unsubscribe link contained in our advertising emails for the future.

If winners are photographed (e.g. for publication on the Internet, on social media channels) or photos are taken in connection with the prize (e.g. meet & greet), these photos may be used by us and/or the partner for corporate communication and external publication in connection with the competition or campaign. 

For statistical purposes, we anonymously analyse how many participants have taken part in a competition or campaign. This analysis does not draw any conclusions about individual participants. 

2.16 Cookies & other identifiers. We use cookies and other identifiers and tracking technologies ("trackers") such as the Apple ID, "web beacons", "tracking URLs", "pixels" and "tracking scripts". These are small transparent image files or lines of code that are contained in our services and emails and record how you interact with them.

Cookies are text files that are sent from our web server to your browser during your visit to our website and stored on your computer for later retrieval. You can select in your browser settings that no cookies are stored on your computer or that the storage of only certain cookies is permitted. You can also view and delete the stored cookies there. If you block cookies, you may not be able to use all the functions of our website.

Necessary cookies are required for the website to function and cannot be deactivated. They are usually only set in response to user actions, such as making your privacy settings, logging in, or filling in forms. You can block these cookies in your browser, but some parts of the website will not work. No personal information is stored in these cookies.

Performance cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website. Performance cookies allow us to understand how popular pages are and see how visitors use the website. The information in these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our website and we will not be able to analyse the performance of the website in this regard.

Functional cookies enable improved functionality and personalisation of the website. They may be set by us or by third-party providers whose services we have included on our pages. If you do not allow these cookies, some or all of these functions and services may not work properly.

Marketing cookies contain identifiers and collect device and access data in order to tailor personalised advertising on our websites to your individual interests. Online advertising networks that we work with also collect device and access data on our websites. This enables us to show you adverts on websites and in apps from other providers that match your interests (retargeting). If you do not allow these cookies, you will be shown less targeted advertising. Marketing cookies can be blocked without affecting the navigation and operation of the website.

Pixel tags, web beacons and trackers are tiny graphics and/or small blocks of code that are placed on websites, in adverts or in our emails. They enable us to determine whether you have carried out a certain action, for example whether you have accessed a website or opened an email. This allows us to measure the response to our communications and improve our websites and advertising campaigns.

You can find an overview of the cookies used here.

2.17 UK regulation of digital services & reporting obligations as a digital platform operator   As a Platform Operator (within the meaning of Part 1 2(4)(c) of The Platform Operators (Due Diligence and Reporting Requirements) Regulations 2023)  (“Platform Operation Regs”), we are legally obliged to collect certain information from an owner (who is a “Seller” within the meaning of the Platform Operation Regs) in the United Kingdom or any partner jurisdiction. 

Owners are obliged to provide the following information upon request: Name, date of birth, address, telephone number and e-mail address; Tax Identification Number (National Insurance Number  or business registration number for UK residents); bank account details; if sellers are registered as a business, the relevant VAT registration number. Owners are required to update this information if it changes.  As part of our due diligence, we may require a copy of an identity or other document to confirm the details provided. 

As a platform operator, we transmit the legally required profile data, financial account IDs including account holders, the revenue generated via the platform less platform fees and taxes and the number of transactions on the platform per quarter to HM Revenue and Customs in any quarter in which the owner was an active seller on the Camplify Platform. We are required to lodge this information annually with HM Revenue and Customs and to provide owners with a summary of the lodged information.  

Camplify must retain copies of reports lodged with HM Revenue and Customs for 5 years. 

2.18 Device and access data. To provide the Camplify platform and related services, we process the technical data generated when using Internet services, to provide the functions and content offered and to display them on your device. Device and access data is generated, for example, when using:

• Websites
• Apps
• Social media pages
• E-mail newsletter, if the newsletter interaction is recorded

Device and access data includes the following:

• General device information, such as information on the device type, operating system, configuration (e.g. language settings, system authorisations), information on the Internet connection (e.g. name of the mobile network, connection speed) and the app used (e.g. name and version of the app).
• Identification data (IDs), such as session IDs, cookie IDs, unique device IDs (e.g. Google Advertising ID, Apple Ad ID), third-party account IDs (e.g. social plug-ins, social logins, or PayPal ID) and other common Internet technologies to recognise your web browser, your device or a specific app installation.
• Access data that is automatically transmitted by apps and web browsers each time web servers and databases are accessed, for example standardised information on the content accessed (such as file name and format) as well as information on server access (e.g. amount of data transmitted and error codes), on your device (e.g. device type, operating system, software, device identifiers, IP address), the previously visited page and the time of access

3. Who will my data be shared with?

3.1 Companies of the Camplify Holdings Limited Group. Camplify Co (UK) Limited is part of the Camplify Holdings Limited Group, which also includes the following companies ("CHL Group"):

Camplify Co (Australia) Pty Ltd, Newcastle, Australia;

Plataforma Camplify España SL, Madrid, Spain

Camplify Co (Portugal) Unipessoal Lda, Lisbon, Portugal

PaulCamper (Germany) GmbH, Berlin, Germany

MyWay Insurance Pty Ltd, Newcastle, Australia

MyWay Insurance Europe GmbH, Berlin, Germany

Within the CHL Group, many systems and technologies are shared to offer services in a more secure and consistent manner. The companies and departments that process data are those that are required to fulfil our contractual and legal obligations or to fulfil their respective functions within the group. Camplify Co (UK)  has entered into agreements with the other companies in the CHL Group that ensure lawful data processing at a UK level of data protection.

3.2 Technical service providers. We work together with technical service providers. If personal data is processed outside the United Kingdom in a "third country", it is possible that a lower data protection standard applies in the third country than in the United Kingdom. In these cases, we ensure that the UK data protection requirements are met, through agreements or guarantees from the service providers.

3.3 Payment service providers. We work together with one or more payment service providers and forward payment data to them for this purpose. We have entered into services and   data processing agreements for this purpose. Payment service providers also process personal data on their own account. You can find out more about this in the "Payments" section of this privacy policy. Further information on the processing of personal data by payment service providers can be found in their privacy policies.

3.4 Authorities. We forward data to the relevant authorities where we are legally required to do so. In particular, we are required, under UK legislation on reporting obligations of digital platform operators, to provide certain data to HM Revenue and Customs (see section 3.17 of this Privacy Policy).

4. Deletion of data  We store personal data for as long as is required for the purposes stated in this privacy policy, including to fulfil our contractual and legal obligations or when your consent has been given. Personal data may also be stored for other purposes to the extent, and for as long as, the law permits, for example to make or defend legal claims.

Deletion may be preceded by "blocking" for legal reasons. In the case of "blocking", access rights are restricted and other technical and organisational measures are taken to ensure that only a small number of employees can access the data in question for the previously defined purposes (e.g. employees of the finance department as part of an audit).

Blocking takes place in the following cases, for example:

• Contract, booking and payment data must be stored for a statutory period of up to  seven years in accordance with commercial and tax regulations. After this period has expired, the data will be permanently deleted.
• In certain cases permitted by law, for example if the data concerned is still required for the further processing of the contract or to make or defend a potential legal claim, we are entitled to initially block the data instead of deleting it immediately. The final deletion of such data takes place when the statutory limitation periods have expired.

Your user account will be deleted at your request. Your user account can also be deleted if you have not used our services for five years.

- Right of access pursuant to Art. 15 UK GDPR
- Right to rectification pursuant to Art. 16 UK GDPR
- Right to erasure pursuant to Art. 17 UK GDPR
- Right to restriction of processing pursuant to Art. 18 UK GDPR
- Right to information pursuant to Art. 19 UK GDPR
- Right to data portability pursuant to Art. 20 UK GDPR
- Right to object pursuant to Art. 21 UK GDPR
- Right to withdraw the declaration of consent under data protection law pursuant to Art. 7 (3) UK GDPR
- Right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 UK GDPR

Information on exercising your rights:

• The best way to exercise your rights is to write to support@camplify.co.uk
• Please enclose sufficient proof of identity with your request for information so that we can ensure that your data is not disclosed to third parties.
• You can change many of your details yourself in your customer account.
• Where data processing is based on your consent, you can revoke your consent at any time
• You can object to the processing of your data for marketing purposes, including direct marketing (also in the form of data analyses) at any time without giving reasons.
• If we base the processing of your data on a balancing of interests in accordance with Article 6(1)(f) UK GDPR, you can object to the processing. When exercising an objection, we ask you to explain the reasons why we should not process your data. In the event of your justified objection, we will examine the situation and either discontinue or adapt the processing or inform you of our compelling legitimate grounds on which we may continue the processing.
• You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory 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.