Privacy & Cookies Policy
This policy explains how TradingTests ("we", "our", "us") collects, uses, stores and protects your personal information when you use our website and peer-to-peer test swap service. We are committed to handling your data transparently and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications Regulations 2003 (PECR).
About This Privacy Policy
This privacy policy applies when you visit or use our website at tradingtests.co.uk and any related services we provide. It explains what personal data we collect, why we collect it, how long we keep it, who we share it with, and what rights you have.
We are the data controller for personal data collected through this service. Our contact details are set out in Section 11.
We may update this policy from time to time to reflect changes in our practices or in applicable law. Where we make material changes, we will notify you by email or by displaying a prominent notice on the site before the changes take effect. The updated policy will always be available at this URL with a revised "last updated" date.
Our commitment: TradingTests is a peer-to-peer test date swap community. We collect only the data we genuinely need to operate the service. We do not sell your personal data to third parties, and we never will.
Information We Collect
We collect and process the following categories of personal data:
Data you provide directly when registering or using our service:
- Your name and email address
- Your mobile telephone number (for instant swap match alerts)
- Your test centre, test date and test time (to match you with swap partners)
- Payment card information โ processed exclusively and securely by Stripe; we never see, handle or store your card details
- Any correspondence you send to our support team
Data collected automatically when you use our website:
- Device type, browser type and operating system
- IP address and approximate geographic location
- Pages visited, time spent on pages and navigation patterns
- Referring URL and ADI partner referral code (where applicable)
- Cookie and tracking technology data (see Section 6)
We do not collect special category data (such as health data or data revealing racial or ethnic origin) and we do not use automated decision-making or profiling that produces legal or similarly significant effects on you.
How We Use Your Data
We process your personal data only where we have a lawful basis to do so under UK GDPR. The table below sets out each purpose, the data used and the legal basis:
| Purpose | Legal basis |
|---|---|
| Providing the swap matching service โ matching you with local learners who want to swap test dates in your area | Performance of our contract with you (Article 6(1)(b) UK GDPR) |
| Sending instant swap match alerts by email and SMS | Performance of our contract with you (Article 6(1)(b) UK GDPR) |
| Processing your payment securely via Stripe | Performance of our contract; compliance with legal obligation (Article 6(1)(b) and (c) UK GDPR) |
| Sending order confirmations and service communications | Performance of our contract with you (Article 6(1)(b) UK GDPR) |
| Attributing referral commissions to ADI partner instructors | Legitimate interests โ operating our partner programme (Article 6(1)(f) UK GDPR). We confirm the signup only; we do not share your test details. |
| Improving our service through aggregated usage analytics | Legitimate interests โ developing and improving our platform (Article 6(1)(f) UK GDPR) |
| Preventing fraud, abuse and maintaining platform security | Legitimate interests; compliance with legal obligation (Article 6(1)(c) and (f) UK GDPR) |
| Sending marketing emails about TradingTests services (if opted in) | Your consent (Article 6(1)(a) UK GDPR). You may withdraw consent at any time by clicking "unsubscribe" in any marketing email. |
| Complying with legal and regulatory requirements | Compliance with legal obligation (Article 6(1)(c) UK GDPR) |
Where we rely on legitimate interests as our legal basis, we have carried out a balancing test to ensure our interests do not override your rights and interests. You may request details of that assessment by contacting us.
How We Share Personal Data
We do not sell, rent or trade your personal data. We share data with third parties only where strictly necessary to operate the service, as follows:
- Stripe Inc. โ payment processing. Stripe processes your card data as an independent data controller subject to their own privacy policy. We receive a transaction reference and confirmation only.
- Email and SMS delivery providers โ to send you swap match alerts and service confirmations. These providers act as data processors under our instruction and are contractually bound to protect your data.
- Analytics providers โ we use Google Analytics with IP anonymisation enabled. Aggregated, anonymised data only is used to improve our platform.
- ADI partner instructors โ where you sign up via an instructor's referral link, we confirm the signup event to attribute their commission. We do not share your test details, test date, mobile number or any other personal data with instructors.
- Competent authorities โ where we are required to disclose data by applicable law, court order, or to protect the vital interests of a person, or to prevent or detect crime.
- Business successors โ in the event of a merger, acquisition or asset sale, your data may be transferred to a successor entity. We will notify you before your data becomes subject to a different privacy policy.
All third-party processors are subject to written data processing agreements requiring them to protect your data to a standard consistent with UK GDPR.
How Long We Keep Your Data
We retain your personal data for no longer than is necessary for the purposes for which it was collected. Our standard retention periods are:
- Account and membership data โ retained for the duration of your membership and for 3 years thereafter, in case of any dispute or legal claim.
- Payment records โ retained for 7 years in accordance with our obligations under UK tax and accounting law.
- Support correspondence โ retained for 2 years from the date of your last contact with us.
- Analytics data โ retained for a maximum of 26 months in Google Analytics (anonymised).
- Marketing consent records โ retained until you withdraw your consent, plus 1 year thereafter as evidence of the consent.
Where we are required by law to retain data for a longer period, we will do so. At the end of the applicable retention period, your data will be securely deleted or anonymised.
Children's Privacy
TradingTests is a service for UK learner drivers. In the United Kingdom, a provisional driving licence may be held from the age of 17. Our service is available only to users aged 17 and over.
Under 17? Our service is not directed at, and should not be used by, anyone under the age of 17. We do not knowingly collect personal data from anyone under 17. If you believe a person under 17 has provided us with their data, please contact us immediately at support@tradingtests.co.uk and we will delete it promptly.
Cookies Policy
TradingTests uses cookies and similar tracking technologies in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR). When you first visit our site, you will be shown a cookie consent banner that lets you choose which categories of cookies to accept. Non-essential cookies are only set with your consent.
You can manage or withdraw your cookie consent at any time by clearing your browser cookies and revisiting the site, or by adjusting your browser settings. Withdrawing consent to analytics or marketing cookies will not affect your use of the service.
For more information about cookies and how to manage them, visit aboutcookies.org or the ICO's guide at ico.org.uk.
Third-Party Websites
Our platform contains links to third-party websites, most notably the official DVSA booking portal at gov.uk. TradingTests is not responsible for the privacy practices, content or availability of any third-party site. We encourage you to read the privacy policy of any site you visit via a link from our platform.
All changes to your DVSA booking are made by you directly on gov.uk. TradingTests does not access, control or manage your DVSA booking at any point.
Your Rights
Under UK GDPR, you have the following rights in respect of the personal data we hold about you. You may exercise any of these rights by contacting us at support@tradingtests.co.uk. We will respond within one calendar month of receiving your request.
Right of Access (Article 15)
Request a copy of the personal data we hold about you, along with information about how we use it.
Right to Erasure (Article 17)
Request deletion of your personal data where it is no longer necessary for the purpose collected, you withdraw consent, or you object and we have no overriding legitimate grounds.
Right to Rectification (Article 16)
Request correction of inaccurate or incomplete personal data we hold about you without undue delay.
Right to Restriction (Article 18)
Request that we restrict processing of your personal data in certain circumstances, such as while we verify a dispute about accuracy.
Right to Object (Article 21)
Object at any time to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.
Right to Portability (Article 20)
Receive your personal data in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible.
Right to Withdraw Consent
Where we process your data on the basis of consent (e.g. marketing emails, non-essential cookies), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to Complain (Article 77)
Lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
We will not charge a fee for exercising your rights unless your request is manifestly unfounded or excessive. We may ask for proof of identity before responding to certain requests.
International Transfers
TradingTests is operated from the United Kingdom. Some of our third-party service providers โ including Stripe (USA) and Google (USA) โ process data outside the UK. Where personal data is transferred outside the UK, we ensure that appropriate safeguards are in place in accordance with Chapter V of UK GDPR. These include:
- Transfers to countries with UK adequacy regulations in place
- Use of the International Data Transfer Agreement (IDTA) or UK Addendum to the EU Standard Contractual Clauses
You may request details of the safeguards we rely on for any specific international transfer by contacting us.
Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. Our measures include:
- HTTPS/TLS encryption across the entire site
- Payment data processed exclusively by Stripe under PCI DSS compliance โ we never receive, handle or store card details
- Role-based access controls restricting access to personal data to authorised personnel only
- Regular review of our technical and organisational security measures
No method of transmission over the internet is entirely secure. While we take every reasonable precaution, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify you directly without undue delay.
Contact Us & Data Controller Details
TradingTests acts as the data controller for personal data collected through this service. If you have any questions, concerns or requests regarding this privacy policy or your personal data, please contact us:
Data Controller: TradingTests (operated under licence by Brooklands LLC)
Email: support@tradingtests.co.uk
Website: tradingtests.co.uk
Registered operator: Brooklands LLC, 3500 S Dupont Highway, Dover, Delaware, US 19901
If you are not satisfied with how we handle your request or complaint, you have the right to lodge a complaint directly with the UK Information Commissioner's Office:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Telephone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF