Privacy Policy

Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your circumstances and, where you require our finance broking services, your financial situation (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, email address, date or birth, National Insurance number and vehicle registration plate. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

We may collect and process the following data about you:

Information you provide to us at the time of registering to use our site, subscribe to our service, search for a product, place an order or enquiry on our site, advertise on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, car details.

if you contact us, we may keep a record of that correspondence or call;
we may also ask you to complete surveys that we use for research purposes although you do not have to respond to them;
details of transactions you carry out through the site;
information we may collect from social networking sites;
technical information, including but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, internet service provider (ISP), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
details about your visit, 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 any phone number used to call our customer service number.
Information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
In the event that you are required to make any payment to us, we will not be storing any specific payment details on our databases because all transactions will be processed through the relevant payment application.
If you require finance we may be able to introduce you to a third party. As part of this process we may need to collect details relation to loans and credit commitments, personal credit history, sources of income and expenditure, and any pre-existing finance products and the terms and conditions relating to these.

The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your requirements we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes outlined above.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from relating to the service like advertising your car for sale, setting up expiry date reminders like MOT, Car Insurance, Service due etc. we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you via our website. In certain circumstances you may also provide information to us verbally and in writing, including email.

When advertising your vehicle for sale we will collect your name, email address, telephone number along with your postcode in order to provide a positioning of each vehicle within our database, this allows potential buyers to locate vehicles for sale within a set radius of a chosen location.
You will also be required to supply the vehicle registration number of the vehicle you wish to sell along with payment details (processed externally).
If your advert expires we may contact you via phone or email to give you the option to renew your advert.
We supply a customer to customer email service that allows individuals who are viewing your advert to contact you via a link displayed on your advert i.e. without exposing your email address. We use this to disable any potential harmful or spurious links that may expose you to fraudulent activity. The use of the customer to customer email service is mandatory for security provisions. We reserve the right to monitor and retain all communications via the email service for security monitoring purposes.
If you register or place an advert on the Website, we will need to collect your email address to send you communications about how to access and manage your account (available within the “My Autotrader” section of the Website). You can access this area at any time in order to update your details or change your options regarding marketing communications from Autotrader and/ or selected third parties. Autotrader will only use your information for marketing purposes where you have agreed to this.
Vehicle Registration Numbers are required in order to place an advert on the Website. If you have opted in for 3rd party marketing then your vehicle registration number may be used to supply relevant offers and services including, without limitation, insurance quotations, vehicle history and credit checks, vehicle valuations and such other services as are developed by Autotrader from time to time. As part of the provision of these services, the third party authorised may need to disclose the Vehicle Registration Number to another third party for example, without limitation, an insurer, insurance panel or credit reference agency. Autotrader will not disclose the Vehicle Registration Number to any person carrying out vehicle searches on the Website, however, if he Vehicle Registration Number is displayed in photographs then the details are visible and non-approved other parties may use them.

We may also obtain some information from third parties, for example, credit checks, searches of information in the public domain. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

First Party Cookies

Login\Registration: When you login or register, we use certain keys from the cookie to remember who you are, for your current visit or returning visits, saving you time to login again. We store username, email address, postcode (if applied) and location (if applied). Whenever you are not logged in, we use a non-personally identifiable cookie to understand the number of unique visitors who look at the adverts on the site.
Internal Tracking: To understand the response that we are getting to our used car advertisers on the site, we use a cookie to store some information about the search you have performed.
Vehicle Search & Enquiries: we need to store some information in cookies related to the searches or enquiries you have been performing. For example, whenever you perform any searches, we need to store the identifiers for those vehicles and adverts or if you send an enquiry (without logging in) we store your enquiry details in cookie which are retrieved next time you trigger an enquiry for better user experience. We store the postcode you have entered for searches to enable us to show you the distance you are from the vehicles in the adverts, and the makes and models of vehicles you are currently searching. We also record related information about the postcode you supply, including the longitude and latitude of the postcode. Some of this information may also be used to bring you more relevant display adverts across our site.

Analytical/performance cookies (Third Party)

Google Analytics: We use Google Analytics to carry out statistical analysis of page use, page interactions and paths through the Website to evaluate and develop our Website. This is known as ‘digital analytics’. We may also record certain information that customers provide during a Website purchase or other process.

This information allows us to understand individual behaviours and needs more accurately. For more information on how Google uses the data collected via this service, see here: http://www.google.com/policies/privacy/partners/

To opt out of being tracked via Google Analytics, you can also use Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout
Hotjar: To help us understand how visitors are interacting with our website, Hotjar records visitors sessions. The cookes stored will record HTML changes that happen while your visitor uses your pages, Mouse movements, Mouse clicks, Scroll movements, Keystrokes only for whitelisted input fields, Browser viewport size changes.

To opt out of being tracked via Hotjar, you can use Hotjars’s opt-out option: https://www.hotjar.com/legal/compliance/opt-out
Facebook: The Facebook pixel is an analytics tool that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website. We use pixel data to make sure our ads are being shown to the right people, Build advertising audiences, Unlock additional Facebook advertising tools.

Targeting cookies

Google AdSense: We use third-party advertising companies to serve ads when you visit our Website. These companies may also use cookies, over which we have no control. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you.
Google AdWords: We use google adverts for our marketing purpose and to monitor conversions for any campaigns which are running, they may serve cookies.

What happens to Your Personal Data when it is disclosed to us?

We use information held about you in the following ways:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information services that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
to maintain, protect and improve our site;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer;
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for example finance partners, car history check, credit score and GAP insurance;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Databases which check the registration of any vehicle being advertised on the website.
Where we are required by law, court order or any governmental or regulatory authority to disclose information;
When disclosure is vital to the maintenance of our operations;
During the sale or transfer of assets; and
In accordance with the Act.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a postal area). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Sharing Your Personal Data

We may share your information with selected third parties including:

We will send your personal information to dealers and relevant third parties to enable them to provide you with the services and products that you have requested through the Website.
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.
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Databases which check the registration of any vehicle being advertised on the website.
Where we are required by law, court order or any governmental or regulatory authority to disclose information;
When disclosure is vital to the maintenance of our operations;
During the sale or transfer of assets; and
In accordance with the certain provisions under the General Data Protection Regulation.

Storage

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. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We do not store any card details on our server. All payments are processed through Sage Pay secured payment gateway. We only store user details which is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 site; 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.

The site includes features to allow you to share information with other users and on other selected social networking websites and apps. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely. (i.e. your credit broking activities)

Your rights in relation to Your Personal Data

You can:

request copies of Your Personal Data that is under our control
ask us to further explain how we use Your Personal Data
ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Personal Data to another organisation should you wish
change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact us via email : info@exoticsempire.com

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.