Privacy Policy | External Transport Manager

Last updated: 30 July 2026

This Privacy Policy explains how Box 4 Digital Group Ltd (T/A External Transport Manager) (“we”, “us”, “our”, “ETM”) collects, uses, shares and protects personal data when you use externaltransportmanager.co.uk, its marketplace, directories, member areas and ETM Desk software (together, the “Platform”). We are the controller for account, marketplace, payment and service-administration data. Where a business user enters personal data about drivers, workers or other people solely to manage its own operations in ETM Desk, that user or business is generally the controller and we process the data to provide the service under section 8 of our Terms.

We are committed to handling personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy is written in plain English so you can understand your rights and how we use information.

Controller details: Box 4 Digital Group Ltd (T/A External Transport Manager), company number 17253991, Suite 114 Business First, Davyfield Road, Blackburn, Lancashire, BB1 2QY. Contact: info@externaltransportmanager.co.uk · 0208 088 8371.

1. The personal data we collect

Depending on how you use the Platform, we may collect:

Registration and account data, such as name, email address, telephone number, business name, account type, username and password.
Profile and listing data, such as your business description, services, qualifications, accreditations, regions covered, course details and images.
Operator register data, publicly available information imported from the DVSA operator register, such as operator name, licence details and location, to create unclaimed listings.
Enquiry and lead data, the contents of “Request TM Support” requests and other enquiries, including contact details and request requirements.
Payment data, directory memberships and claimed listings may be collected by Direct Debit through GoCardless, while paid ETM Desk subscriptions and card services are collected through Stripe. We do not store full bank or card details. We receive limited information such as mandate, subscription or payment status, payment amount and plan.
ETM Desk records, information entered or uploaded to organise transport-management work, which may include operator and licence details; vehicle and trailer records; driver and personnel details; inspection, maintenance and defect records; tasks, reviews, diary entries, documents, photographs, reports, calendar items, audit events and other compliance evidence.
Atlas assistant data, prompts, the one-operator context selected for a request, generated responses and usage information. Atlas conversations are not automatically saved as Desk documents; if a user expressly saves a conversation, it becomes part of the ETM Desk records.
ETM Repute Score data, calculations and component indicators derived from current records in the Desk account. This is an internal operational indicator, not a DVSA, Traffic Commissioner or other regulatory rating.
Technical, usage and analytics data, such as IP address, device and browser type, pages viewed and referring pages, collected through server logs, cookies and similar technologies.
Communications, records of correspondence when you contact us by email, phone or through the Platform.

2. How and why we use data, and our lawful bases

We use personal data only where we have a lawful basis under UK GDPR. The main bases are:

Contract, to create and manage an account, provide the chosen directory or ETM Desk plan, process membership and deliver requested services.
Legitimate interests, to operate, secure, improve and promote the Platform; connect members; handle enquiries and route leads; prevent fraud and abuse; and provide a useful listing service. We balance these interests against individual rights.
Consent, for non-essential cookies and analytics, and for direct marketing where consent is required. Consent can be withdrawn at any time.
Legal obligation, to comply with legal, tax, accounting and regulatory duties.

Specific purposes include: setting up and administering accounts; publishing listings and profiles; routing “Request TM Support” and other enquiries to appropriate members; taking payment through GoCardless or Stripe for the relevant service; providing ETM Desk record-keeping, document, task, calendar, reporting and audit functions; responding to queries; sending service and account messages; maintaining security and preventing misuse; and analysing usage to improve the Platform.

When Atlas is used, ETM sends the prompt and only the selected context for one operator to contracted AI inference providers over an encrypted connection so they can generate a response. Atlas output assists the user’s work and is not used by ETM to make legal or similarly significant automated decisions about a person. It must be reviewed before reliance.

ETM does not automatically save Atlas prompt or response text as a Desk document. We record a daily quota counter and an audit event showing that Atlas was used, including time, operator, action and model, but not the prompt or response. A conversation expressly saved by the user becomes a Desk document and follows the same storage and retention rules.

The ETM Repute Score is calculated from records in the account to help its user identify gaps and organise follow-up work. It is not a regulatory rating, legal status or guarantee of compliance, and ETM does not use it to make legal or similarly significant automated decisions about a person.

If you add information about drivers, employees or other people to ETM Desk, you or your organisation are responsible for having a lawful basis, providing any privacy notice required by law, keeping the information relevant and accurate, and responding to those people’s rights. We process that information under the data-processing terms in section 8 of our Terms.

3. How we share data

We do not sell personal data. We share it only as needed to run the Platform:

With other members, when a person sends an enquiry or “Request TM Support” request, relevant details, including contact information and requirements, are shared with the member or members selected to respond. Information published in a listing or profile is visible to members and visitors.
With ETM service providers acting as processors, including managed website hosting, email delivery, analytics, backup and secure off-server document storage. ETM Desk documents are mirrored to a Hetzner Storage Box away from the web server. These providers may process data only to provide the contracted service, subject to appropriate terms.
With payment providers, GoCardless acts as an independent controller for payer and merchant payment data it processes to provide and administer its payment services. Stripe acts as our processor where it processes payment data on our instructions and may also act as an independent controller for payment administration, fraud prevention, security, legal, regulatory, payment-network and service-improvement purposes. Their own privacy information applies to their controller processing: GoCardless Privacy Centre and Stripe Privacy Policy.
With the Atlas inference provider, when an authorised user invokes Atlas. The current route uses Google Vertex AI through the europe-west1 regional endpoint in Belgium. Google processes customer personal data as a processor under the Google Cloud Data Processing Addendum. We do not opt in to provider use of Atlas content for model training.
Where required by law, to comply with legal obligations or court orders, or to protect our rights, staff, members or the public.
In a business transfer, if our business is reorganised, sold or transferred, subject to this policy and applicable law.

Google does not use Atlas prompts or responses to train or fine-tune AI/ML models without our permission or instruction. If Google’s automated safety systems flag suspected misuse, Google may securely retain the relevant prompt for up to 90 days in the selected region solely to investigate potential abuse. See Vertex AI data retention.

Atlas is configured to use Vertex AI’s europe-west1 regional endpoint in Belgium. Belgium is recognised as providing adequate protection under UK data-protection rules. Google notes that selecting a regional endpoint is not an absolute data-residency guarantee, and Google or its subprocessors may process data elsewhere as permitted under the Google Cloud Data Processing Addendum.

The Google Cloud Platform Terms incorporate the Google Cloud Data Processing Addendum. The Addendum states that Google acts as a processor for customer personal data and provides the transfer terms applicable under UK GDPR where a restricted transfer occurs. You may ask for information about the safeguard applicable to a particular transfer, and a copy where one can lawfully be provided, by emailing info@externaltransportmanager.co.uk.

4. How long we keep data

We apply the following maximum periods unless a longer period is required by law, needed for an active legal claim or dispute, or requested by a customer controller for a documented lawful purpose:

Account and profile data, for the life of the account, then deleted or anonymised from live systems within 30 days after a verified closure request. A limited closure, consent or dispute record may be kept for up to six years where needed to establish legal rights.
Enquiry and lead data, for up to 24 months after the last activity on the enquiry.
Payment and financial records, normally six years after the end of the relevant financial year to meet tax and accounting obligations.
ETM Desk records, for the life of the Desk account. Cancelling a paid Desk plan does not delete them; the account moves to the then-current Desk Free limits. On verified account closure, the customer controller may request export and deletion or deletion without export. Deletion from live systems and primary off-server document storage is normally completed within 30 days.
Atlas records, the daily quota counter is kept only as needed to enforce the daily limit. The content-free Atlas-use audit event remains in the Desk oversight diary for the life of the Desk account. Saved Atlas conversations are Desk documents. Provider-side handling of unsaved prompts and responses is described in section 3.
Analytics data, user-level and event-level analytics data is kept for no more than 26 months; aggregated reports that no longer identify a person may be retained longer.
Communications, for up to 24 months after the matter is resolved, or longer where linked to an active account, transaction, complaint or legal claim.

Residual copies of deleted live data may remain in isolated database or website backups until the next successful scheduled replacement. Our current backups retain a latest copy rather than a historical archive and are normally replaced within 24 hours. Backup data is not used for normal operations and, if restored, is subject to the same deletion requirement.

Publicly sourced operator-register listings are retained while useful to ETM search and are removed or updated on request, when claimed, or when we establish that the source record is no longer current.

5. Cookies and analytics

We use cookies and similar technologies for essential functionality, analytics and to improve the user experience. Non-essential cookies can be controlled through our cookie banner and browser settings. See our Cookie Policy for details.

6. Your rights

Under UK GDPR you may have the right to:

be informed about how we use data;
access personal data we hold about you;
rectify inaccurate or incomplete data;
erase data, where applicable;
restrict processing in certain circumstances;
data portability, for certain data in a portable format;
object to processing based on legitimate interests or to direct marketing;
withdraw consent where we rely on it.

Your right to object to direct marketing: You may object at any time to our use of your personal data for direct marketing. We will stop that processing. Use the unsubscribe link in a marketing email or contact info@externaltransportmanager.co.uk. This right is separate from the other rights above and there is no charge for exercising it.

To exercise a right, contact info@externaltransportmanager.co.uk. We normally respond within one month and may need to verify identity first. Where a request concerns customer-controlled ETM Desk data, we may refer it to the relevant customer controller and assist that controller as required.

7. Security

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. Measures include controlled account access, private document storage, encrypted transmission, secure hosting, off-server mirroring and operational backups. No system is completely secure, but we take reasonable steps to safeguard information.

8. Marketing

Where you have agreed, or where permitted by law, we may send information about the Platform and relevant services. You can opt out at any time using the unsubscribe link or by contacting us.

9. Complaints

If you have concerns about how we handle personal data, please contact us first so we can investigate. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority, at ico.org.uk or 0303 123 1113.

10. Changes to this policy

We may update this Privacy Policy from time to time. The “Last updated” date shows the latest version. Material changes, including a material new ETM Desk subprocessor, will be brought to account holders’ attention where appropriate.

11. Contact us

Box 4 Digital Group Ltd (T/A External Transport Manager)

Suite 114 Business First, Davyfield Road, Blackburn, Lancashire, BB1 2QY

Email: info@externaltransportmanager.co.uk · Tel: 0208 088 8371