We have updated our Policy. This Policy has been designed to provide greater transparency and has been set out so that it is easier to read and understand. We will continue to treat your personal information with care and respect.
Collection of personal information
We collect personal information from you (such as name, address, telephone number, email address etc) when you complete registration or enquiry forms or send emails to us. Please do not submit your personal information to us if you do not wish us to collect it. Furthermore, we may record any telephone calls made to telephone numbers included on the Site. Further information on the collection and use of data is set out below.
1.1 ”We/us/our” means GWH Ltd number 09511401, whose registered office is at 35 Ballards Lane London N3 1XW.
1.2 We respect your privacy and we are committed to protecting it and to complying with applicable data protection and privacy laws, including the Data Protection Act 1998 (the “Act”). We have provided this Policy statement to help you understand how we collect, use and protect your personal information when you visit any Site
1.3 By visiting the Site you are accepting this Policy and you expressly consent to our use and disclosure of your personal information as disclosed in this Policy. However, you may visit and browse the Site without disclosing any personally identifiable information about yourself.
1.4 Please note that this Policy may change from time to time and, if it does, the latest version will always be available on the Site.
COLLECTION AND USE OF DATA
2.1 The personal information we collect from you includes:
(a) personal information obtained from you via the Site;
(b) personal information you provide about yourself in order to sell or buy a vehicle or manage your account on the Site;
(c) personal information you send to us in personal correspondence such as emails, letters or over the telephone; and
(d) personal information we receive from other users or third parties about you and/or your activities.
The type of personal information we collect could include your name and address, vehicle registration mark, telephone and fax numbers, e-mail addresses and financial and credit card information.
2.2 The personal information you provide to us will be used for the purposes of administration, processing the purchase of a vehicle, business development, trend analysis and marketing. We will also use it to create offers specifically designed to meet your needs and as set out in clause 3 below.
2.3 The personal information you provide to us will be used for the purposes of administration, processing the sale and purchase of a vehicle (including registering interest in vehicles for sale and advertising vehicles for sale), business development, trend analysis and marketing. We will also use it to create offers specifically designed to meet your needs and as set out in clause 3 below.
2.4 Please note that there may be times when we use third parties to store and process your information on our behalf. On any such occasions, we will require any such third parties to strictly comply with our instructions and to not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information on this way.
2.5 We may store, process and/or transfer personal information to countries outside of the EEA, especially for servers in the US. If you do not agree to this procedure you should not use our products or services. Your personal information, on some occasions, is transferred outside the EEA to a carefully selected third party, for our data management and business purposes, in particular, for certain outsourced data processing undertaken by organisations on our behalf. By using our products and/or services you consent to our transferring your personal information to countries outside the EEA, if necessary, for our legitimate business purposes as outlined above. We will take reasonable steps to ensure your personal information is adequately protected.
The data protection standards required by US law are not equivalent to EEA standards. To comply with the adequacy requirements of the European Data Protection Directive 95/46/EC, any above mentioned third party will be a participant in the Safe Harbor program developed by the U.S. Department of Commerce and the European Union or have entered into an agreement with us that includes the EC model clauses approved by the European Commission.
2.6 We automatically track certain personal information based upon your behaviour on the Site using cookies and other devices. We use this personal information to do internal research on our users’ demographics, interests, and behaviour to better understand our users. This personal information may include the address of the webpage that you just came from (whether this is on the Site or not), which webpage/website you next go to (whether this is on the Site or not), what browser you are using, and your IP address.
2.8 Please note that we will not hold your personal information for any longer than is reasonably necessary or required by law.
DISCLOSURE OF DATA
3.1 We may share your personal information with:
(a) business partners, suppliers and subcontractors for the performance of any contract we enter into with you;
(b) analytics and search engine providers that assist us in the improvement and optimisation of the Site;
(c) credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you; and
(d) if you have provided your consent, third party marketers of auto-related products, motor manufacturers and other services that we believe may be of interest to you. In addition, your personal information may sometimes also be used by us and members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (as defined in section 1159 of the Companies Act 2006) to inform you about changes to the Site, new services and offers that you might find interesting and for database maintenance.
In your correspondence to us, please set out what it is that you would like to see changed about your personal information.
3.2 Your personal information may also be shared with auditors or contractors or other advisers auditing or advising us on our business operations.
3.3 We co-operate with law enforcement agencies, as well as other third parties, to assist in the enforcement of laws. We can (and you authorise us to by the acceptance of these terms through the continuous use the Site) disclose any personal information about you to such law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate in connection with any investigation by such law enforcement agencies or other government officials.
3.4 We may transfer, sell or assign any of the personal information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business (or any part of our group).
3.5 We have the appropriate security measures in place in relation to how your personal information is stored and used, and who can see it. We use industry standard practices to safeguard the confidentiality of your personal, identifiable information, including “firewalls” and “secure socket layers”. While such measures help stop any unauthorised disclosure of your information, no security system is impenetrable and we cannot guarantee the security of our system.
3.6 In addition, the transmission of personal information via the internet is not completely secure. Once we have received your personal information, we will use strict procedures and security measures to try to prevent unauthorised access. However, we cannot guarantee the security of your personal information, any more than any other company can. Please note therefore that any transmission of your personal information to the Site is at your own risk and we cannot accept any liability for the loss, theft or misuse of any personal information which you have provided to us if there is a security breach.
3.7 Where we have given you (or where you have chosen for you) a password which enables you to access certain parts of the Site, you are responsible for keeping the password confidential. We ask you not to share a password with anyone.
YOUR RIGHTS IN RELATION TO YOUR INFORMATION
4.1 The Act gives you the right to access personal information held about you. You can write to us at any time to obtain a copy of your personal information, to have any inaccuracies corrected and/or updates made. Please write to[the Compliance Manager] at the address set out at clause 3.1 above.
4.2 In writing to us, please quote your name and address. We would be grateful if you could also provide brief details of the personal information of which you would like a copy or which you would like to be corrected/updated.
4.3 We may require proof of your identity before providing you with details of any personal information we may hold about you. We also reserve the right to charge £10 (ten GBP) to cover the administration costs involved in providing you with a copy of your personal information.
ONLINE INTERACTIVE FACILITIES
5.1 If at any time the Site offers any chat functionality, notice board facilities, forums, newsgroups etc. (“Online Interactive Facilities”) we may collect the personal information that you disclose. Such personal information will be used in accordance with this Policy. Please note that we cannot be responsible for other parties’ use of the personal information which you make available to such third parties through any Online Interactive Facilities on the Site. Please be careful about what personal information you disclose in this way.
5.2 If you post or send offensive, inappropriate, illegal or objectionable content while you are in any of our Online Interactive Facilities, we may use your personal information to stop such behaviour, and where we believe that you are, or may be, in breach of any applicable laws, we may use your personal information to inform the police or requisite law enforcement agencies.
The law on cookies changed in May 2011. Under the revised regulations, the requirement is not just to provide clear information about the cookies, but also to obtain consent from users or subscribers to store a cookie on their device. It has been designed to protect online privacy by making consumers aware of how personal information about them is collected by websites, and enabling them to choose whether or not they want it to happen. Please read on for more information.
6.1 What is a cookie? A cookie is a small piece of data that is sent from our web server to your browser, which is saved on the hard drive of your computer, smartphone or other device (“your device”).
A cookie cannot:
- read data off your hard disk or read cookie files created by other sites;
- damage your system;
- run programmes on your computer; or
- deliver viruses.
There are two broad classes of cookie: session and permanent.
These are used to keep track of information needed by a user and their browser on their journey through a website. Session cookies have a short lifetime and expire within a few minutes of the user leaving the site. Occasionally we will use 30 Day cookies which are similar to Session cookies but last a bit longer. They remember basic date to help improve the service you receive from us (for example, remembering vehicles that you have viewed in the last 30 days).
These are stored on your computer and are not deleted when the browser is closed. This is so they can retain your preferences for a particular website, allowing those preferences to be used in future browsing sessions.
Permanent cookies can be used to analyse users’ surfing behaviour within the Site, so that we can improve our services and allows us to prioritise our enhancements to the Site.
- remember that you have used the Site before; this means we can identify the number of unique visitors we receive to different parts of the Site. This allows us to make sure we have enough capacity for the number of users that we get and make sure that the Site runs fast enough;
- to keep you logged in for the duration of your visit, which enables you to complete certain actions on the Site, for example, move from one page to another within the Site, adding cars to a shortlist, using watchlists and viewing catalogues;
- store your preferences or your user name and password so that you do not need to input these every time you visit the Site;
- customise elements of the layout and/or content of the pages of the Site for you;
- collect statistical information about how you use the Site so that we can improve the Site;
- gather information about the pages on the Site that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”; and
- enable basic web traffic analysis using Google Analytics.
When you access the Site you will receive a message advising you that if you continue to use the Site, you are consenting to cookies being placed on your device in order to maximise your experience on the Site and allow us to make improvements
Information is collected by reference to the IP address that you are using and includes information about the county and city you are in, together with the name of your internet service provider. The information is sometimes used to place interest-based advertisements on the Site which it is believed will be relevant to your market segment. For more information about this type of interest based advertising, and about how to turn this feature off please visit www.youronlinechoices.com/uk/.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Visiting www.allaboutcookies.org will provide information on settings within your browser as well as other useful information on cookies. Please note, however, that by blocking or deleting cookies used on the Site you may not be able to take full advantage of the Site if you do so.
Further guidance on how to control and delete cookies can be found at http://www.allaboutcookies.org. Please note that removing some of our cookies may seriously disrupt your use of the Site and some features may not work as intended.
We do use some cookies from trusted third party sources to enable us to provide you with certain features on the Site and have included any relevant third parties on our cookie list so that you can control the cookies they place more easily:
6.4 What about Hyperlinks? The Site may sometimes contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies and we urge you to review them. They will govern the use of any personal information you submit or which is collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such third party websites is at your own risk.
6.5 What about Flash Cookies? A Flash Cookie is a type of cookie which is collected via Adobe Flash Player, and is a piece of software which you probably have on your device to watch videos or podcasts online. We may use Adobe Flash Player to display video or image content. It may not be possible to block or restrict or block Flash Cookies using your browser settings, however, information on how to control flash play privacy and security settings is available from the Adobe website at: http://www.adobe.com/products/flashplayer/security
USE OF YOUR PERSONAL INFORMATION SUBMITTED TO OTHER WEBSITES
7.1 We cannot be responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from the Site or you linked to the Site from a third party website.
7.2 We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have any concerns or questions.
CHANGES TO THIS POLICY
8.1 If we need to change our Policy at some point in the future to reflect our data collection and disclosure practices, we’ll post the changes at least 30 days before they take effect. Our use of personal information gathered while the current policy is in effect will always be consistent with the current policy, even if we change that policy later.