Privacy & Cookies Policy

About This Privacy Policy

This privacy policy applies when you visit or use our website at adiswap.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.

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 — 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:

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:

• Payment Processing. PCI – DSS complaint processors process 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 — 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 — we use Google Analytics with IP anonymisation enabled. Aggregated, anonymised data only is used to improve our platform.
• ADI partner instructors — 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 — 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 — 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 — retained for the duration of your membership and for 3 years thereafter, in case of any dispute or legal claim.
• Payment records — retained for 7 years in accordance with our obligations under UK tax and accounting law.
• Support correspondence — retained for 2 years from the date of your last contact with us.
• Analytics data — retained for a maximum of 26 months in Google Analytics (anonymised).
• Marketing consent records — 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

Adi Swap 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.

Cookies Policy

Adi Swap 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. Adi Swap 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. Adi Swap 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@adiswap.co.uk. We will respond within one calendar month of receiving your request.

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

Adi Swap is operated from the United Kingdom. Some of our third-party service providers — including PCI – DSS payments (UK and USA) and Google (USA) — 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 using PCI DSS compliance processors — 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

Adi Swap 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:

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: