Privacy Policy


PACENOTES (“We” or “us”) take your privacy seriously and are fully committed to handling the information we collect from you in a secure and responsible manner. We are dedicated to protecting and respecting your privacy.

This policy (together with our PaceNotes Terms and Conditions of use and any other documents referred to in it) sets out the basis upon which any personal information we collect from you, or that you provide to us, will be processed by us when you are using our app (the “App”). Please read this policy carefully before you use the App and/or register with us. If you do not agree with the ways in which we intend to use your personal information, then please do not continue to use the App.

For the purpose of the General Data Protection Regulation (“GDPR”) including any subsequent legislation, the data controller is TRAK (GLOBAL SOLUTIONS) LIMITED, a company registered in England and Wales under company number 06944694, whose registered office is at Global House, Westmere Drive, Crewe, CW1 6ZD.

The App provides a platform for drivers to record information relating to their driving learning instruction so that they can track and evidence their progress and can use that information for the purposes of securing preferential rates on newly-qualified driver car insurance.  If you want to download and use the App then you will need to register with us and agree to our terms of use of the App.  This privacy policy relates solely to your use of the App and the personal data you provide as a result of your usage of the App.

Registering with us means that we will use your details to set up and maintain an account on the App.  Only you and us will be able to access your own personal information and information about your vehicle unless your account is connected to a Driving Instructor that has been approved by us.  When your particular vehicle has been assigned to a Driving Instructor, they and us will also be able to view your personal data on our website.  Details of this set up are provided in our PaceNotes Terms and Conditions.

Whilst we will remain responsible for the personal information that we collect and/or process about you in relation to your use of the App, once your account is linked to a Driving Instructor, they will have full access to all your personal data and analytical and statistical information via the Instructor Portal unless you change your settings on the website to prevent certain information from being shared in this way.  Driving Instructors’ use of any personal information shared with them via the website is subject to their own privacy policies and they will be deemed to be a separate and severable data controller in respect of their collection and processing of your personal information.

By registering with us you are agreeing that we may contact you in relation to the management of your account with us. You can update your preferences by emailing us or writing to us.  Please see the ‘Contact us’ section of this policy for details of who to contact.


Collecting and using your personal information

We may collect and process the following personal information about you for the purposes of administering a contract:

1. Information you give to us

You may give us information about you by:

We may use this information:

2. Information we collect about you

Depending on your settings within the App, we may automatically collect the following information:

We will use this information:

3. Information we receive from and share with other sources

We work closely with the following third parties:


Storage and deletion of your personal information

All personal information you provide to us will be stored on our secure servers or those of third parties or contractors we engage to help us run our business. We will ensure that we keep information for no longer than we need to to give effect to the purpose for which we collected it. The period of time for which we keep personal information depends on any legal retention period to which we are subject and according to business needs. If you have registered with us then we will keep your personal information for at least as long as you are registered with us.

The personal information that we collect from you may be transferred to and held by us, or third parties/contractors at a destination outside the European Economic Area that does not have equivalent data protection laws to those in the UK.  We will put in place appropriate measures for the secure and confidential treatment of such personal information and will inform you before any of your data is transferred outside the European Economic Area.

Where we have given you, or where you have chosen, a password which enables you to access the App, for example when you register with us, you are responsible for keeping this password confidential.  You must not share a password with anyone else.

We will store all your personal information necessary for administering your account on the App (i.e. ‘Information you give us’ and, where relevant, ‘Information we receive from and share with other sources) for as long as you are registered with us.

Disclosure of your personal data to Driving Instructors

The App may automatically upload your personal information to the Driving Instructor that you are connected to on the App in accordance with the PaceNotes Terms and Conditions. Please note that we have no control over any use of your personal information by such parties upon the transfer of your personal information and that their use of your personal information will be dealt with under their own privacy policies. We do not accept any responsibility or liability for these policies or for the processing of your personal information by those parties.  Please check those policies before you submit any personal information to these parties.

Other disclosures of your personal information

We may disclose your personal information to third parties if we are under a duty to disclose or share it in order to comply with any legal obligation, in order to enforce or apply our PaceNotes Terms and Conditions, where we think it appropriate to protect the rights, property, or safety of Trak (Global Solutions) Limited, its staff and contractors and partners, users of the App or others. This includes exchanging information with other organisations for the purposes of the prevention and detection of crime.

We may also share your personal details with any person (and their and our legal and professional advisers for this purpose) with whom we are negotiating any sale, transfer or re-organisation of the business.  If this sale, transfer or re-organisation goes ahead, the acquiring party of the business or part of it may use your personal information in the same ways as set out in this policy.

The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them (including those linked to your location) have their own privacy policies and that we do not accept any responsibility or liability for these policies or for the processing of your personal information by those parties.  Please check those policies before you submit any personal information to these websites.

Your rights

You have the right to access a copy of the information we hold about you, and to ask us to rectify any information which we hold which is incorrect and to ask us to delete your data.  We will endeavour to respond to any request for information without undue delay and will respond at the latest within one month of the date we receive your request.  If we will be unable to meet your request within this timescale, we will write to you setting out the reasons why.  We reserve the right to ask you to specify the information or processing activities to which your subject access request relates.

Any access request will be free of charge, although we may charge you a reasonable fee to meet our administration costs if you request further copies of the same information.

Unless you inform us otherwise, we will provide you with the information you request electronically in a form which is commonly machine-readable.  If you would prefer this information in another format, we reserve the right to make a reasonable charge for our administrative fees associated with converting the information to that alternative format.

Please help us to keep your personal details up to date by promptly notifying us of any changes, for example if you change address or telephone number. If you need to change your personal details or preferences at any time, please log in to your account on the App to change your settings or contact us (please see the ‘Contact us’ section of this policy).

You have the right to complain to the Information Commissioner at, Tel 0303 123 11132.

Changes to our privacy policy

This is the most up to date version of this policy. Any material changes we may make to our privacy policy in the future will be, where appropriate, notified to you.

Contact us

If you have any questions, comments or requests regarding this policy, or you would like to contact our Data Protection Officer, James Hulsken, please contact us at:



Post:     Trak (Global Solutions) Limited, Global House, Westmere Drive, Crewe, CW1 6ZD