CarsVansandBikes – UK's fresh alternative to finding your next vehicle today

PRIVACY POLICY 2021

WHO WE ARE

We are CarsVansandBikes Limited (company number SC675014) and our address is 38 Thistle Street, Edinburgh, Scotland, EH2 1EN (referred to as "We" or "Us" or "Our"). We are the providers of the CarsVansandBikes mobile application software (referred to as the "App") and the website www.carsvansandbikes.com (referred to as the “Site”) (together referred to as the “Platforms”). Our VAT number is 358 3639 63.

We provide the Platforms so that Our members can advertise vehicle details for You to view. “Our Members” include motor dealers and private vehicle owners. We are not a motor dealer.

A reference to "You" or "Your" is a reference to a user of the Platforms or any of Our services.

A reference to “Users” is a reference to individuals using our Platforms or services.

INTRODUCTION

We are committed to protecting Your privacy. This privacy policy (referred to as the "Policy") explains how and for what purposes We use the information collected about You when You use the Site or download and use Our App on Your mobile device (“Device”). Please read this Policy carefully.

If You have a query about information relating to Your vehicle on the Platforms, please contact Us on support@carsvansandbikes.com

CONTACTING US

Unfortunately due to the current climate (Covid-19), there may be a delay in Us receiving and responding to Your postal enquiries and therefore email correspondence is recommended for a quicker response.

If You would like to stop receiving marketing and communications from Us please contact Us via email at marketing@carsvansandbikes.com or please write to the Customer Services Team, CarsVansandBikes Limited, 38 Thistle Street, Edinburgh, Scotland, EH2 1EN.

If you have any questions about this Policy or Our use of Your personal information or would like to submit a subject access request or exercise Your other data subject rights, please contact Our Data Protection Officer/Team via email at dpo@carsvansandbikes.com or please write to The Data Protection Officer/Team, CarsVansandBikes Limited, 38 Thistle Street, Edinburgh, Scotland, EH2 1EN.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

VEHICLES ADVERTISED ON THE SITE
What We collect and where it comes fromWhy We collect itOur lawful basis for processing this personal data
  • In the course of providing Our services, We collect vehicle data such as images of vehicles, including videos and virtual demonstrations, vehicle asking prices, sales history and sold prices, and vehicle addresses.
  • The vehicle data is provided to Us by Our members or other third parties on behalf of those members.

We will use this information for a number of reasons including:

  • to provide the CarsVansandBikes Platforms;
  • to enable Our members to advertise their vehicles to the largest online audience available;
  • to enable potential purchasers to see detailed descriptions and images of vehicles that they may be interested in;
  • to allow Users to see current vehicle trends such as the prices of vehicles for sale in their local area; and
  • for Our own commercial purposes such as to identify trends in the vehicle market, automated survey and valuation tools, and to build vehicle databases.

We have a legitimate interest to process this information. These legitimate interests are:

  • providing a service to Our members by helping them to market vehicles and understand changing market dynamics and evolving trends;
  • providing a service to Our members by advertising vehicles to potential purchasers;
  • providing a service to potential purchasers and tenants so that they know what vehicles are currently on the market and the price of those vehicles; and
  • to provide data services to third parties such as banks, insurance companies and other financial institutions so that they can process this vehicle data for their purposes, including using the data in services such as vehicle valuation models
How long We will keep it for
  • We will stop advertising a vehicle when we are instructed to do so by Our members.
  • However, the vehicle information will remain available on the Platforms as historical vehicle information to allow users to benefit from services such as identifying previous for sale or sold prices (please see the historical vehicle data section below for further information).
HISTORICAL VEHICLE DATA
INFORMATION YOU GIVE TO US
What We collect and where it comes fromWhy We collect itOur lawful basis for processing this personal data

We will collect the information that You give to us when using our Platforms or services:

Enquiries to Our members

  • if You choose to access a particular search feature, request information or fill in a form on the Platforms You may be asked to provide information about yourself, such as:
  • Your name, address and contact details
  • details of the sort of vehicle You are interested in
  • the cost and location of the vehicle, and
  • Your current residential address
  • If You choose to book an appointment to test drive a vehicle via the Platforms, You may be asked to provide more details, including:
  • Your availability to view the vehicle
  • Your preferred test drive date
  • Your driving licence details
  • Your feedback on a vehicle that You have viewed,
  • if You choose to contact a member using the member telephone number on the Platforms, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.

Registered Users and Vehicle Alerts:

  • information that You provide to Us when You register as a CarsVansandBikes User and/or request vehicle email updates such as Vehicle Alerts about when a vehicle is marketed in Your chosen postcode and meeting Your search parameters;

General Use of the Platforms:

  • information that You provide when downloading the App or registering to use the App;
  • information that You provide when participating in discussion boards or other social media functions on Our Platforms and enter into competitions, promotions or surveys available on the Platforms

Communications:

  • information that You provide to Us by corresponding with Us by phone, e-mail or otherwise;
  • if You choose to contact Us by phone or We call You, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls; and

We will use this information:

Enquiries to our members:

  • to make sure that You receive the benefit of the CarsVansandBikes service. This may include:
  • transferring Your vehicle enquiry to Our member advertising that vehicle so that they can respond to Your enquiry. Some of Our members may use lead handling agencies who handle and process your enquiry on their behalf; or
  • sending Your request to book a vehicle viewing to Our member advertising that vehicle and for Us to confirm Your booking by email or text on Our member’s behalf;
  • sending Your name, address and contact details to Our member when You request information on a vehicle they are advertising, so that they can contact You;
  • enabling Us to send you a link to access an online viewing of the vehicle You have enquired about; and
  • allowing You to provide Our member with feedback on the vehicle once You have viewed it;
  • for training and monitoring purposes where calls are recorded;
  • to profile your lead activity on Our Platforms or telephone calls to Our Members for monitoring and training purposes and to enhance the service You receive from Our Members. If You want to know more about this, see “Lead Profiling” below

Registered Users and Vehicle Alerts:

  • to provide You with the benefit of services for registered Users only;
  • to provide Vehicle Alerts to You for vehicles marketed on our Platforms that meet Your search criteria;

General Use of the Platforms:

  • to provide the Platforms to You and enable You to download the App;
  • to enhance the services that You select on Our Platforms;
  • to process any queries that You have about CarsVansandBikes or its members;
  • to customise and enrich Your experience on Our Platforms;
  • to contact You for your views on Our services and to notify You occasionally about important changes to Our Terms of Use or this Policy or developments to Our Platforms or services;
  • to deliver relevant advertising to You whilst You are on the Platforms;

Communications:

  • to process and resolve any queries that You may have;
  • for training and monitoring purposes where calls are recorded

We have a legitimate business interest to process this information. These legitimate interests are:

  • Enquiries to Our members: to provide a service to Our members and/or to provide a service to You;
  • Registered User and Vehicle Alerts: to provide You with Our services;
  • General Use of the Platforms: to enable You to download and use the App and gain information about the use of Our Platforms and any improvements that can be made as well as providing advertising space to Our members and third parties;
  • Communications: to ensure that Your queries are addressed;
  • for training and monitoring purposes where calls are recorded.
How long We will keep it for

We will store the information summarised above for the following periods:

Enquiries to Our members
  • all enquiry data will be kept for two years from the date on which You last used our Platforms or Our services. After that it will be erased or anonymised so that the data no longer identifies You;
  • telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted;
  • profiling data will be kept for a shorter time period, as described in “Lead Profiling” below.
Registered Users and Vehicle Alerts:
  • Information that You provide to Us when You register as a CarsVansandBikes User will be kept for as long as you have an active account setup on CarsVansandBikes. The personal data relating to Your account will be deleted when You delete Your account or if Your account has been inactive for 5 years (from Feb 2021), whichever is earlier.
General Use of the Platforms:
  • information that You provide when downloading the App, registering to use the App or for accessing in-App services will be retained for as long as You have the App installed on Your device;
  • information that You provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years; and
  • information that is provided when You interact with Us through social media functions will only be retained on the social media platforms which You use to contact us. We will not copy or store it separately. This data will be retained for as long as You keep it on your social media accounts.
Communications:
  • Information that You provide to Us when We correspond by phone, e-mail or otherwise will be retained for the later of 18 months from the date of communication or until Your query is resolved.

INFORMATION WE RECEIVE FROM THIRD PARTIES (OTHER THAN OUR MEMBERS)

What We collect and where it comes fromWhy We collect itOur lawful basis for processing this personal data
  • We may receive information about You if you use any of the other websites We operate or the other services We provide via the App. In this case we will have informed You, when we collected the data, that it may be shared internally and combined with data collected on the Platforms.
  • to allow You to participate in the interactive services available on Our Platforms or to participate in competitions or promotions via Our Platforms;
  • to pass Your searches and messages on to Our members to help them communicate with You directly and to provide a more personalised service to You. This may include contacting You about other relevant vehicles, adding You to their enquiry database for future contact and offering You their additional services;
  • to provide services and information to Our members, which they can use to benchmark their performance;
  • to customise and enrich Your experience on Our Platforms; and
  • to contact You for Your views on Our services and to notify You occasionally about important changes to Our Terms of Use or this Policy or developments to Our Platforms or services.
  • We have a legitimate interest to process this information. These legitimate interests are:
  • enhancing the service that You receive on the Platforms;
  • to provide a service to Our members so they can respond to enquiries; and
  • providing information necessary to enable Us to provide a competitive, cost effective service.
How long We will keep it for

We will store this personal data for two years from the date on which You last used our Platforms or services at which point it will be erased or anonymised so that the data no longer identifies You.

INFORMATION WE COLLECT ABOUT YOU

What We collect and where it comes fromWhy We collect itOur lawful basis for processing this personal data
  • This is different to “information you give Us” because it relates to technical data that We collect. We may:
  • collect technical information that has the potential to identify You, including the type of Device You use, a unique identifier (for example, Your Device's IMEI number), the internet protocol (IP) used to connect Your computer to the internet, the MAC address of the Device's wireless network interface, or the mobile phone number, Your login by the Device, mobile network information, Your mobile operating system, the type of mobile browser You use and time zone setting, the browser plug-in types and versions, operating system and platform;
  • collect information about Your visit to the Site, including the full uniform resource locators (URL) clickstream to, through and from Our Site (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page; and
  • details of Your use of our App or Your visits to our Site via the App, the resources that You access and the advertisers and partners that You contact;
  • use GPS technology on Your Device to determine your current location. Some of our location-enabled services require Your personal data for the feature to work;
  • set a unique application number which is contained within the App. When You install or uninstall the App or when the App searches for automatic updates, that number and information about your installation, for example, and the type of operating system, may be sent to Us; and
  • combine technical information with other information that We have about You to help Us with Our processing of Your information as set out in this Policy.
  • We will use the information summarised above:
  • to provide the Platforms to You;
  • to conduct reviews that assist Us in the improvement and optimisation of Our Platforms;
  • to ensure that content from Our Platforms is presented in the most effective manner for You and for Your device;
  • to administer Our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • as part of Our efforts to keep Our Platforms safe and secure;
  • to customise and enrich Your experience on Our Platforms;
  • to provide You with GPS enabled functionality; and
  • to identify what versions of the App are being used or when the App is uninstalled from a device
  • We have a legitimate interest to process this information. These legitimate interests are:
  • to help ensure the on-going security of the Platforms;
  • enhancing the service that you receive on the Platforms; and
  • providing information necessary to enable us to provide competitive, cost effective services.
  • If You wish to use a location data service which engages your Device’s GPS tracker, You will be asked to consent to your data being used for this purpose upon registering to use the Platforms. You can withdraw your consent at any time by turning off the location services settings for the Platforms on Your Device.
How long We will keep it for

We will store this personal data for two years in order to allow Us to review and monitor normal traffic patterns and trends on Our Platforms. After two years this data may be kept in an anonymous form. We will store the unique application number for as long as the App is installed.

LEAD PROFILING

We may from time to time profile Your activity when using Our services or our Platforms. This profiling is limited in its scope to telephone and email enquiries You send to Our members. It only takes place to help Us and Our members understand what sort of vehicles You may be interested in and any vehicles You may have for sale, and to categorise Your activity to help Us and Our members determine how likely You are to require services from Our members. Members may then contact You to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing Your personal data). You can always object to Our profiling by emailing Us here dpo@CarsVansandBikes.com.

Any profiling data that We hold about You will only be kept for a period of 12 months from the date of the last telephone or email You have sent to a CarsVansandBikes member.

USE OF YOUR DATA FOR MARKETING AND COMMUNICATIONS

Sometimes we may Use your personal information to provide marketing messages to You. You can opt out of marketing and other communications at any time by contactingmarketing@CarsVansandBikes.com. You can always make use of the Platforms without having to agree to marketing. The types of things that We may do include:

  • providing direct marketing advertisements and communications to You via email, text, post or telephone;
  • making suggestions and recommendations to You and other Users of Our Platforms about goods or services that may interest You or them;
  • communicating with You on third party social media platforms; and
  • monitoring the effectiveness of Our direct marketing communications and Your responses to it.

REMOVING VEHICLE DATA FROM THE SITE

If You have any concerns about the vehicles advertised on the Platforms, please contact Us at dataquality@CarsVansandBikes.com and We will endeavour to resolve the issue promptly.

If You have concerns about historical vehicle information about a vehicle featured on Our Platforms and You can prove to us that You have a valid association to that vehicle, please contact Us atsold.prices@CarsVansandBikes.com

WHO HAS ACCESS TO YOUR PERSONAL DATA?

We retain access to all personal information that We have collected from You or about You. Once Your information has been passed to one of Our members in the course of providing Our services (most typically when You communicate with a motor dealer through Our Platforms) then that CarsVansandBikes member will have a copy of the information that You have provided within Your enquiry and Your contact details which they will use to get in touch with You. In relation to vehicle data, it is provided to Us by Our members (or third parties that act on their behalf). Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of Your information by any of Our members.

When Our service is available via the websites of Our partners, those partners may have access to Your information. We may also have links to other websites from Our Platforms. We are not responsible for the content, security, privacy policies and practices of any other websites, even if You access them using links from Our Platforms or if You can access Our Platforms or use Our services from them. We recommend that You check the policy of each website that You visit and make sure that You are comfortable with the terms of such policies before providing any personal information.

If Our business is sold or merged, or if We sell or buy any business or assets, We may disclose Your personal data to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If We offer or supply a service to You that is provided on Our behalf by a third party, We may have to pass Your information to them in order to deliver the service. The categories of third parties (who are acting as Data Processors which means they are responsible for processing personal data on behalf of Us) include: telephone call recording and Our support ticketing systems. We may also use third parties to provide services on Our behalf which may include processing (but not using themselves) Your information e.g. to complete partial addresses or to augment the information We hold about You. In either case, We will not pass Your information to anyone who is not also subject to adequate privacy commitments in Our contract with them.

We will not otherwise disclose, sell or distribute Your information to any third party without Your permission unless We are required to do so by law or to obtain professional advice.

WHERE DO WE STORE YOUR PERSONAL DATA?

The data that We collect from You may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA, but We are under a duty to make sure that Our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Policy. By submitting Your personal data to Us, You agree to this transfer, storing or processing.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to Our Platforms; any transmission is at Your own risk. Once we have received Your information, We will use strict procedures and security features to try to prevent unauthorised access.

We follow strict security procedures to ensure that Your personal information is not damaged, destroyed or disclosed to a third party without Your permission and to prevent unauthorised access to it. The computers that store the information are kept in a secure facility with restricted physical access and We use secure firewalls and other measures to restrict electronic access. If We are working with third parties, We will require them to have in place similar measures to protect Your information.

Only employees who need access to Your information to perform a specific job are granted access to personally identifiable information. We may require You to co-operate with Our security checks before We disclose information to You. If You are a registered User, You can update the personal information held in Your My CarsVansandBikes account (that You give us) at any time by viewing YourMy CarsVansandBikes page.

Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Platforms, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

YOUR RIGHTS

You have the right to ask Us not to process Your personal data at any time.

You have the right to use Our Platforms without consenting to marketing and the communication services that We provide. We will inform You (before collecting Your data) if we intend to Use your data for such purposes or if We intend to disclose Your information to any third party for such purposes. We always use the most recently submitted form to be Your current consent status. If You are a registered User, but not signed in when You submit a form, We will not be able to Use Your saved settings so will deem Your consent choice to be as per the form You submit at the time. You can exercise Your right to prevent such processing by selecting the specific options in the fields or forms when You become a registered User.

You have a right to request access to or rectification of Your personal data which We hold about You. You also have a right to erase Your personal data, to restrict the processing of Your personal data and the right to receive Your personal data that You have provided to Us, the right to object to Our processing of Your personal data and a right to request that We transmit Your personal data to another data controller.

Where We process Your personal data because You have given us Your consent to do so, You have the right to withdraw Your consent at any time.

To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this policy.

You have the right to complain to the Information Commissioner’s Office if You feel unhappy with the way We process Your data. Please visit www.ico.org.uk for more information.

COOKIES AND TRACKING

Like many website and App providers, We use "cookies" to enable Us to personalise Your visits to Our Platforms, simplify the signing-in procedure, keep track of Your preferences and to track the usage of Our Platforms. For full details about what cookies We set and why We use them, please see Our Cookie Policy.

CHANGES TO THIS POLICY

We may change the terms of this Policy at any time. Any changes We may make to this Policy in the future will be posted on the Site or displayed on-screen when You use our App.

You may be required to read and accept any new Policy terms to continue Your use of the App. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App.

Please check back frequently to see any updates or changes to this Policy, as You will be deemed to accept such changes from Your continued use of our Platforms.

Issue date: 5th January 2021