COOKIE & PRIVACY POLICY

INTRODUCTION

Carxtra respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our products or services or websites or otherwise and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Carxtra collects and processes your personal data through your use of our products and/or services or otherwise, including any personal data you may provide through relevant websites when you sign up to our newsletter, request product information, purchase a product or service or take part in a competition, or any personal data of yours provided to us through third parties.

The Carxtra products or services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Carxtra is a brand owned by cap hpi lmited, a company registered in England and Wales with registered number 8033745 and whose registered office is Capitol House, Bond Court, Leeds, West Yorkshire, LS1 5EZ is the controller and responsible for your personal data (collectively referred to as ”Carxtra”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:
Full name of legal entity: cap hpi limited
Email address: info@carxtra.com
Postal address: Carxtra (C/O cap hpi limited) Capitol House, Bond Court, Leeds, West Yorkshire, LS1 5EZ
Phone: +44(0)3333703412

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This privacy notice may be updated by us from time to time. This version was last updated on May 25th, 2018 and historic versions can be obtained by contacting us. The most up-to-date version of the Privacy Notice can be found at www.Carxtra-group.com.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

In any of our relevant websites, there may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the personal identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data generally includes, to the extent applicable:names, username or similar identifier, title, date of birth, gender, Vehicle Registration Mark ("VRM"), and Vehicle Identification Number ("VIN")

Contact Data generally includes, to the extent applicable: billing address, delivery address, email address and telephone numbers.

Financial Data generally includes, to the extent applicable: bank account and payment card details

Transaction Data generally includes, to the extent applicable: proof of payment or details about payments to and from you and other details of products and services you have purchased from us.

Technical Data generally includes, to the extent applicable: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on devices you use to access this website.

Profile Data generally includes, to the extent applicable: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data generally includes, to the extent applicable: information about how you use our website, products and services.

Marketing and Communications Data generally includes, to the extent applicable: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice

We generally do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

In certain limited circumstances we may collect photographic ID documentation from you for purposes of verifying identity, if we do so we will ask for your consent before processing such ID data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions.  You may give us your Identity, Contact, Financial, Profile, and Marketing and Communications Data among others by filling in forms or by corresponding or communicating with us by post, phone, email or otherwise. This includes personal data you provide when you:

- apply for, inquire about, or purchase our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing materials to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback

Automated technologies or interactions. As you interact with our relevant websites, we may automatically collect Technical, Usage, and Profile Data among others about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical, Usage, and Profile Data among others about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

- Technical, Profile, or Usage Data from the following parties:

(a) analytics providers such as Google;
(b) advertising networks; and 
(c) search information providers.

- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer  (a) Identity
(b) Contact 
Performance of a contract with you 
To process and deliver your order and/or providing services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us 
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications 
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) 
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey 
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications 
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 
To enable you to partake in a prize draw, competition or complete a survey  (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications 
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) 
To administer and protect our business and relevant website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  (a) Identity
(b) Contact
(c) Technical 
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you  (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences  (a) Technical
(b) Usage 
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 
To make suggestions and recommendations to you about goods or services that may be of interest to you  (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile 
Necessary for our legitimate interests (to develop our products/services and grow our business) 
To prevent and aid public authorities (such as the police) in preventing and apprehending fraud or crime, and to provide fraud prevention services  (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Profile
(h) Usage 
Necessary for our legitimate interests and the legitimate interests of third parties/public authorities (to prevent and apprehend fraud or crime and to protect innocent parties from being a victim of fraud or crime) 
To administer and provide our warranty services with respect to the accuracy of vehicle data and to establish and prove losses, damages for the purpose of warranty claim processing and settlement  (a) Identity
(b) Contact
(c) Financial
(d) Transaction 
Necessary for our legitimate interests and the legitimate interests of third parties/customers (for the processing of warranty claims and for the establishment, proof, and settlement of warranty claims) 
To provide our National Mileage Register (“NMR”) related services and for conducting NMR investigations on vehicles suspected of having its odometer tempered with  (a) Identity

(b) Contact 

Necessary for our legitimate interests and the legitimate interests of third parties/customers/public authorities (for the purposes of conducting NMR and mileage investigations to ensure the accuracy of the mileage reading on vehicles and to prevent fraud) 

Necessary for our legitimate interests and the legitimate interests of third parties/public authorities (to prevent and apprehend fraud or crime and to protect innocent parties from being a victim of fraud or crime)

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Carxtra group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not affect our processing of your personal data for other non-marketing purposes such as providing a product/service to you, warranty registration, product/service experience, customer service or support, or other transactions, etc.

COOKIES

Our websites use cookies to enable certain functionality, and for user analytics. By using our site, you agree that we can place these cookies on your device.

Most websites set cookies and browsers are typically set up to accept cookies, at least for the duration of a single browsing session. If you wish to change your cookie preferences you can do so using your browser settings. Your browser’s ‘help’ function will show you how to do this.

We have always used cookies on this website, and as part of a change in legislation, all websites are now required to provide additional information on what cookies are, how they are used and what benefits they bring. These changes will not affect the way in which you currently use our website.

When we include links to other websites, please bear in mind they will have their own privacy and cookie policies that will govern the use of any information you submit. We recommend you read their policies as we are not responsible or liable for their privacy practices.

WHAT ARE "COOKIES"

Simply, cookies to help websites distinguish individual browsers from each other. Cookies are small pieces of data which are stored for a website by your browser. Every time it loads a page your browser will send that page back the cookies it had set previously. This allows a website to connect your interactions together.

Cookies can’t be shared between websites, and each site can only read and update the cookies it set itself. However when you visit our a single website your browser may connect to others, and each of these may set cookies of their own. You can find out more about the cookies set when you visit our websites.

A cookie cannot give anyone access to your computer and doesn’t mean we’re collecting new information from you. If you want more information about cookies, you can get further details on allaboutcookies.org.

Some third parties we work with and link to via this website will have their own cookie policy and may ask you to set your cookie preferences with them.

WHAT COOKIES DO WE SET?

The types of cookies we use are divided into four categories:
Functional cookies: these cookies let you move around our websites and use all their options. Without them, the website would not work as it should.
Analytics and performance cookies: these help us improve the way our website works to give improved performance. They tell us how each page is used, which ones are most commonly viewed and whether any errors are reported.
Customisation cookies: these cookies remember basic information that you’ve entered into the site, so next time you visit our website it’s all there for you. We do not store personal information in cookies.
Targeting cookies: these cookies help make sure adverts you see on your browser are relevant and useful to you because the cookie has detected what you’re looking for.

When you visit our sites the following domains may set cookies to track the performance of our social media and paid advertising. You can find out more about their policies by clicking on their name:
.facebook.com - Facebook
.twitter.com (and t.co) - Twitter
.bing.com - Bing
doubleclick.net, google.com, google.co.uk. googleapis.com, googleleadservices.com - Google
 

We rely on the tools from the following partners for analytics and performance:
Google Analytics - find out more here
HotJar - find out more here
 

TARGETING COOKIES

 
As part of our marketing, we partner with advertising networks who use cookies to ensure that particular advertisements are not shown to you too many times and to collect information about the types of websites that you visit so that they can show you advertising that is relevant to your particular interests. You can use the following website to control your online advertising preferences: http://www.youronlinechoices.com/uk/your-ad-choices.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary

External Third Parties as set out in the Glossary

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

More specifically, and without limiting the generality of the foregoing, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers for tax, financial auditing, and record keeping purposes.

In some applicable circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research, analytics, or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Glossary below for a more detailed explanation about these rights:

Request access to your personal data;

Request correction of your personal data;

Request erasure of your personal data;

Object to processing of your personal data;

Request restriction of processing your personal data;

Request transfer of your personal data;

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us via the contact information set out above.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you and the marketplace the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in cap hpi limited, acting either as joint controllers or processors and who are based in the EEA and provide IT and system administration services and undertake information reporting.

External Third Parties

Service providers acting as processors based in the EEA who provide IT and system administration services.

Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the United Kingdom who require reporting of processing, financial, or transaction activities in certain circumstances.

Public authorities such as the police, acting as joint controllers, based in the United Kingdom who require personal data in certain circumstances to prevent or apprehend crime or fraud.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.