- Available Car Limited
The Available Car Group of Companies – which we will refer to as ‘the Group’ in this document – is made up of two related businesses: Available Car Limited and Graham Bell Holdings Limited. For simplicity throughout this notice, ‘we’ and ‘us’ means the Group. As required through the Data Protection Act 2018, we the ‘group’ are the ‘Data Controller’ when assessing finance, Insurances and Warrantee’s and then the ‘Data Processor’ throughout the agreement stage. We determine the purposes for which and the manner in which personal data is processed. This means that the data controller exercises overall control over the ‘why‘ and the ‘how‘ of a data processing activity.
- About this Privacy Notice:
This Data Privacy Notice contains key information and is a summarised version of our full Data Privacy policy, which is available upon request.
- Contract
Where you are providing data to form a ‘Contract’ it is necessary for us to use your information to carry out checks for identity and suitability before we provide those services to you. In these circumstances your data is being processed as it is necessary for the purposes of entering into a contract for services that you have requested.
- Consent
When collecting your personal data, we will always make it clear to you which data is necessary in connection with your enquiry. We use consent as our legal basis for processing personal data where the processing is conducted in order to send communications to you about our services, to exchange information for aftersales surveys or further marketing purposes. You may withdraw your consent at any time by following the contact instructions at the bottom of this privacy policy.
We would typically use this legal basis for processing your personal data in order to process an application for a vehicle loan or insurances so that you can enter into an agreement with one of our panel of funders.
This legal basis for processing personal data is also used when processing personal data of those who wish to enter into a contract for employment with Available Car Limited.
- Legal Obligation
There are circumstances when we are compelled by a legal obligation to process certain personal data about individuals. This is typically a legal basis for processing ‘proof of identity’ data when confirming a candidate’s right to work in the UK. This will be relevant to those applicants who have successfully completed the initial stages of the recruitment process.
- Legitimate Purposes
Data protection law also allows us to use personal information for our genuine and legitimate reasons as long as we respect your rights and freedoms. Such uses include checks for to prevent fraud and money laundering.
Legitimate interests are also our legal basis when considering the period of time to retain customer records, in order to protect the commercial interest of the company e.g. from suspected fraud or to defend against complaints for negligence.
When we rely on our legitimate interests as the legal basis for processing the information in your personal data, we will carefully consider and balance any possible effect this may have on you and your rights.
- Secondary Use of your data
Additionally, some of the information that we collect may also help us develop new and improved products and services to meet our customers’ needs. If we use your data for these secondary purposes then we either obtain your consent for those purposes or anonymise the data so that it no longer contains information that can identify you.
- How we use your personal data:
We use your data to process any requests or orders you may place on our website or in our showrooms. If we don’t collect your personal data during our interactions with you, we won’t be able to process your requests for keys to our vehicles for security reasons and/or we wouldn’t be able to comply with our legal obligations should you place an order. We also use your data to respond to your queries or complaints. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- Keeping your data safe
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, technological and managerial procedures to safeguard and secure the information we collect. It is also a condition of our contracts with any data processors that they and their sub-processors have appropriate security measures in place to protect the data being processed on our behalf.
Our security measures are continually improved in line with technological developments.
- Direct Marketing
We will only engage with you via direct marketing channels with your legitimate interest rather than express consent to do so. You have the right to stop us using personal data for direct marketing activity through all channels, or selected channels we will always comply with your request.
- Sharing Personal Data
We may share your data with other companies in our ‘group’ and our Finance and Insurance/Warrantee third party bodies as listed below:
Assurant – (Assurant Group Ltd, Assurant General Insurance Group) Registered Office: Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN
Branko Limited – Registered office: 4b Victoria Road, Linsdale, Leighton Buzzard, LU7 2NT
Black Horse Limited – Registered office: 25 Gresham Street, London EC2V 7HN
Evolution Funding Limited – Registered office: Thompson Close, Chesterfield, S41 9AZ
Santander Consumer (UK) Plc – Registered office: 86 Station Road, Redhill, Surrey, RH1 1SR
Startline Motor Finance Limited – Registered office: 6th Floor 60 Gracechurch Street, London, EC3V 0HR
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some/all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may, from time to time, share such data with third parties, such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, under issue of a court order or at the request of a governmental authority.
9.1. Third Parties
Google Analytics
We use Google Analytics, owned by Google, to collect, monitor, and analyse traffic to Our website.
Google collects data about the device you are using, device type, browser information and device
screen size. Google also collects your IP Address which is used to approximate your location.
Google does not share your IP Address with Us, which in turn does not allow Us to identify you as
an individual.
For further details on how Google Analytics uses and protects your data, please see Google’s privacy policy here. You may also opt-out of Google Analytics tracking by installing this browser plugin, provided by Google.
Liveperson
We use Liveperson to communicate with Our customers, using the live chat widget located on our website.
Liveperson does not share your Transcripts, Surveys or Recordings with any other third party other than the Liveperson customer (Us). If you elect to engage in any communication session or other engagement session using Liveperson’s services, it is up to you to decide what, if any, information to provide during such a session.
To see how Liveperson handles your personal data, please read Liveperson’s privacy policy here.
- What Data do we collect
We will only collect the minimal amount of data required to fulfil your request or our legal obligations and our legitimate interests and includes the following:
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Data
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Reason
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· Name
· Address
· Phone number
· Date of birth
· Email address
· Vehicle information
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Required to respond to your queries submitted via our website
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Digital Footprint (IP Address, Browser Meta Data, Device Meta Data)
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Required for maintaining the security of our systems and to prevent abuse.
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- How Long We Keep Your Personal Information
Your personal information will in principle be retained no longer than necessary for the aforementioned purposes. This means that your personal information will in principle be retained no longer than 7 years after termination or cancellation of your finance or insurance/warranty cover to respond to questions, complaints or enquiries. However, we may retain your personal information longer if this is required to comply with a law or regulation to which we are subject or necessary for us to protect or exercise our rights, to the extent allowed under applicable data protection law.
- Your rights
You have the ultimate right to:
- Information:- To be informed about the processing being carried out by us.
- Access:- Subject to certain exemptions, to obtain a copy of the personal data being processed.
- Rectification: – To have inaccurate data rectified.
- Erasure:- To have personal data erased upon request, subject to certain exemptions.
- Data Portability:- In certain circumstances have automated data returned to you, or sent direct to another controller, in a structured, commonly used and machine-readable format.
- Objection:- The absolute right to object to direct marketing and a qualified right to object to processing based on the controller’s legitimate interests, including profiling.
- Automated decision-making:- Not to be subject to decisions based solely on automated processing.
If we do not handle your validated request within 1 month of receipt, then you have the right of referral to the ICO who act as the data protection arbitrator. Details of how to contact the ICO are at https://ico.org.uk/global/contact-us/
- Contact
Group Compliance Officer
We have a ‘Group Compliance Officer’ who is responsible for matters relating to privacy and data protection. The Data Protection Officer can be reached at the following address:
Sarah Gadsby
Group Compliance Manager
Available Car Limited
sarahgadsby@availablecar.com
- Changes to this privacy notice:
It is likely that we will need to update this Privacy Notice from time to time. You are welcome to come back and check it whenever you wish.
This Privacy Policy was last modified on 17th June 2021.