- Who we are
Trusted Dealers Ltd is a UK digital automotive marketplace that offers a vehicle buying and selling process. To provide you with the full range of Trusted Dealers products and services, we need to collect and process information about you.
- the Trusted Dealers website at www.trusteddealers.co.uk (the “Website”)
- social media or official Trusted Dealers content on other websites;
- our mobile devices and Applications (“Apps”)
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.
For the purposes of this Policy, the data controller is Trusted Dealers Limited (registered in England and Wales under company registration number 03909628) and whose registered office address is at Trusted Dealers Limited, 201 Great Portland Street, London, W1W 5AB.
Our Privacy Promise
Trusted Dealers Limited (“Trusted Dealers”, “we”, “us”, “our”) is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it.
It’s important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.
- What information Trusted Dealers collects about you;
- How Trusted Dealers collects and uses information about you;
- Whether Trusted Dealers discloses your details to anyone else;
- The choices available to you regarding the personal information you provide to us;
- When and how your data may be shared with third parties.
Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.
We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and 2011 and the General Data Protection Regulations (GDPR), and including any amendments or updates to these and any equivalent or successor applicable laws and regulations.
- Information collected and how we use it
Trusted Dealers collects the following information:
Information you provide when you browse or use services on the Website
You will need to supply your postcode in order to use our vehicle search facility. We will use this to present adverts matching your search criteria with the distance from your selected location.
If you book a test drive of a new vehicle, or request a quote or brochure, through the Website you will need to provide your name, email address, postal address and telephone number which will be passed to the relevant dealer or other third party. Each request form clearly indicates that you are giving authorisation for your details to be passed to the relevant dealer or other party for them to contact you and action your request.
All conversations and email exchanges are recorded. Any personal information that you disclose on the telephone or via an online form will be accessible to and processed by the Dealer with whom you communicate and will be made available to Trusted Dealers.
When you use the Website we will also collect your IP address.
Information we collect if you use our Mobile Applications
If you choose to download or use our Mobile Applications, or access one of our mobile optimised sites, we may receive information about your location and your mobile device, including a unique identifier for your device.
We may use this information to provide you with location-based services, such as advertising, search results, and other personalised content. Most mobile devices allow you to control or disable location services within the mobile device’s settings. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your device.
How we use the information we collect
We use the information we collect to:
- provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services.
- generate an overall audience profile of visitors using the Website. We use this information to assist us in developing relevant content on the Website as well as encouraging automotive trade advertisers to place adverts for their stock or promotions on the Website.
- provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email (including where customers have supplied their insurance renewal date information and/or vehicle ownership details).
- support our ‘Send to Mobile’ functionality. This allows visitors to our Website to send details of vehicles for sale to their mobile phone.
- identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.
Lawful basis we use to process your information
We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:
- Consent: To provide information and take actions in relation to services which you have opted-in to receive. This includes where you specifically request for your details to be passed onto a third party (e.g where you are making an enquiry regarding test drive or a vehicle for sale) or where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers).
- Legal Obligation: Where processing is necessary to comply with legal or statutory requirements on us. This may include cooperating with police in relation to their investigations.
- Legitimate interest: To improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, undertake market research and inform our general marketing, to run our business and maintain the security or our Website and services for you, us and other Website visitors and customers.
Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by dealers.
Where you have given consent for Trusted Dealers to process your personal data you may withdraw consent at any time by emailing firstname.lastname@example.org. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.
If you have given consent for your details to be passed to a dealer or other third party your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.
- Disclosure of your information
Trusted Dealers will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:
- We will send your personal information to dealers, vehicle manufacturers, bike manufacturers and relevant third parties to enable them to provide you with the services and products that you have requested or consented to receive details of via the Website or the Apps.
- We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third party platforms (such as the ‘Facebook Recommend’ or Facebook Gestures’ function). Information about your visit to the Website may be collected by these third party providers on these pages. If you browse these pages whilst still also logged in to your account on the third party platform, information collected by the third party may be connected to your account on the third party platform. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
- Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our terms and conditions and any other agreements.
- If we sell or buy any business or assets, in which case Trusted Dealers may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, personal data held by us about our customers may be disclosed to the prospective buyer.
- We may share your personal information with our group companies.
- We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies, automotive advertising companies and/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders. .
We are not responsible for any use of your personal data by these parties except where they act as our processor.
- Where we store your personal data
All information you provide to us is stored securely within the EU, and not transferred outside the EEA unless specifically detailed.
Payment card information, details you provide when requesting dealer or other third party services through the Website and information you provide when using the Chat Service is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the EEA in accordance with their privacy policies. Where we transfer your data outside of the EEA, we will ensure that safeguards are in place to provide similar degree of protection is available to protect it. This may include contractual protections in place with our service providers or transferring your data to countries or parties which are recognised as providing suitable protection by the European Commission.
Certain parties to whom we disclose your personal data may transfer your data outside of the EEA after we disclose it to them as part of their business and administration activities (see above, Disclosure of your information). We are not responsible for any use of your personal data by these parties except where they act as our processor. If you have queries or require more information on how these third parties use your information, including such transfers outside of the EEA, please read their privacy policies or contact them.
Trusted Dealers uses strict procedures and security features designed to prevent any unauthorised access to your data that we hold.
- Retention period
Trusted Dealers will process personal data for as long as necessary to fulfil the purpose we collected it for, including the purpose of legal, accounting and reporting requirements, and for as long as necessary for the prevention and detection of criminal activity. The period for which we process and store the personal data for varies depending on the use you make of the Website and the products and/or services we offer. Where you register an account or place an advert we will retain your data for as long as your account and/or advert is live and a period after your account is closed or advert ends to enable us to satisfy our legal, accounting and reporting requirements.
In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. In the event that Trusted Dealers refuses your request under rights of access, we will provide you with a reason as to why
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing, automated processing or profiling.
- Right to complain to the supervisory authority – you have the right to complain as outlined in paragraph 8 below.
- Complaints and Contact
If you wish to make a complaint about how your personal data is being processed by Trusted Dealers (or third parties as described above), or how your complaint has been handled, in the first instance please email your concerns to email@example.com. You also have the right to lodge a complaint directly with the UK supervisory authority which is the Information Commissioner’s Office and can be contacted via the details at www.ico.org.uk.
If you have any questions regarding the use of your personal data please contact us at: firstname.lastname@example.org
Trusted Dealers Limited, 201 Great Portland Street, London, W1W 5AB