iCashCars Privacy Notice (“Notice”)
iCashCars is a UK digital automotive marketplace that offers vehicle buying and selling services (the “Services”). To provide you with the full range of iCashCars products and services, we need to collect and process certain information about you.
The Services provided by iCashCars involve collecting and processing information and personal data from:
- Automobile Traders, and
- Automobile Sellers/Customers
Automobile sellers provide us with personal data on our Website when they seek valuation of their vehicles. After this first step, our sales team contacts the customer to seek further information and details about the customer and the vehicle.
The Traders provide us with their personal data when they register with us through our website and after the first step of registration is completed, they may be formally registered with iCashCars Trader’s Portal after their information is double checked by us. Once registered on to the Trader’s Portal, the Traders are able to buy leads and subsequently vehicles, through the iCashCars Trader’s App (the “App”).
Thus, the scope of our Services involves collection and processing of personal data relating to automobile traders who seek to get registered on our Trader’s Portal (the “Traders”) and also automobile sellers/customers (the “Customers/Sellers”) who seek to sell their vehicle through our website to us or to any of the Traders registered with iCashCars.
This Notice and our Cookies Policy apply to all visitors to and users of:
- the iCashCars website at https://icashcars.co.uk/ (the ” Website“);
- any iCashCars website that links to this Notice and/or our Cookies Policy
- iCashCars social media accounts;
- iCashCars mobile devices and Applications (“Apps“).
It also applies to anyone contacting us by phone, SMS, e-mail, in letters and other correspondence, in person and via social media.
WHO ARE WE? DATA CONTROLLER AND CONTACT DETAILS
For the purposes of this Notice, the data controller is iCashCars Limited (registered in England and Wales under company registration number 11063712) having its registered office address is at iCashCars Limited, Pinescope, Nine Mile Ride, Wokingham Berkshire.
If you have any questions regarding the use of your personal data please contact us at: [email protected] ,
Data Protection, iCashCars Limited, Pinescope, Nine Mile Ride, Wokingham Berkshire, RG40 3ND.
INFORMATION COLLECTED BY US AND HOW WE USE IT
Account creation by Traders on the website:
If you are a trader and wish to create a trader’s account with iCashCars, we will collect your email address and your chosen password. Further, in order to fulfill the first step of the registration process with iCashCars successfully, you must provide your name and Company name. Other fields like mobile number, postal code, VAT number and website address may also be provided by the Trader.We will use your name and email address to send you communications about your account.
Where you are logged in on Facebook or another social media account and wish to chat with us through Facebook Messenger, we may be provided with limited personal details (including your account ID and email address) and any other information that you voluntarily provide us with through chatting with us.
Legal basis for collecting and processing this information:
- Legitimate Interest
We use your name and email address to register your account and send you service communications about how to access and manage your account.
Information you provide to us if you are using Services on iCashCars:
We may collect, use, store and transfer different kinds of personal information about you, including:
- Identity Data, such as your name, date of birth, gender, National Insurance Number.
- Contact Data, such as your home address, email address and telephone numbers,
- Financial Data, such as bank account details and details of any finance agreements you wish to settle as part of a transaction with us.
- Document Data, such as your V5 vehicle registration document, and copies of your driving licence, passport, utility bill and other documents that verify your identity.
- Transaction Data, including details about payments to and from you, and other details of products and services we may supply, including payment made on your behalf to your finance company to settle a finance agreement.
- Where You Represent A Business Entity, the name of the organization you represent, that organization’s Contact Data, Financial Data and Transaction Data
- Technical Data, including IP addresses, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website,
- Profile Data, which can compiled from valuations made by you, feedback and survey responses,
- Usage Data, including information about how you use our website
- Marketing Data, such as your preferences in receiving communications from us.
How we collect your personal information
We may obtain personal information by directly interacting with you, such as when you:
- use the valuation tool on our website,
- enter into an agreement with us to sell your vehicle,
- enter into an agreement to sell your vehicle with any of the Traders registered on the iCashCars Trader’s Portal (the “ Trader’s Portal”) who have purchased the lead.
- participate with our social media team through an online platform,
- enter a competition, promotion or survey organized by us, or otherwise providing us with feedback,
- correspond with us by phone, email, letters or otherwise.
We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies (such as recognizing you as a returning visitor so we can show you your last valuation).
We may also collect personal information about you from third parties or publicly available sources, including credit reference agencies and third party providers of anti-fraud and anti-money laundering verification services.
We may also collect personal information about you from third parties or publicly available sources, such as:
- providers of technical, payment and delivery services,
- Companies House, or other open-source websites that enable us to validate information to satisfy terms of our contract, for example, confirmation of business/asset ownership, where we suspect or reasonably believe an individual is not acting in accordance with the terms of our contract.
- We obtain information about your car and its ownership from the DVSA, such as MOT records.
How we use your personal information:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- you have given us consent,
- we need to perform a contract we are about to enter into, or have entered into, with you,
- when you are about to enter into a contract with a Trader registered on the Trader’s Portal,
- where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
- where we need to comply with a legal or regulatory obligation.
Payments by Traders:
Traders registered with iCashCars are required to provide card payment details in order to purchase leads and subsequently purchase vehicles. We use third party payment providers to manage all online card payment transactions. Payment card information is collected over a secure online payment gateway provided by:
All payment transactions processed are encrypted. Your payment card information is used solely to process payment for the leads and payments for the vehicles. We retain no record of your payment card details.
Using services on iCashCars as a Seller/Customer:
When using services on iCashCars, you will need to provide certain personal information such as name, email address, telephone number and postcode and details regarding your vehicle (including vehicle registration number, mileage, make and model) to enable us or a Trader/third party to provide you with the services requested. Depending on the service, this information may be passed to a third party.
Legal Basis for collecting and processing this information:
Valuation – You will need to provide details regarding your vehicle in order to obtain a valuation. This may be the vehicle registration number and mileage and/or other details regarding your vehicle such as the make and model.
Vehicle Search facility – You will need to supply your postcode in order to use our vehicle search facility. We will use this information to convey to the Trader who has bought the lead to your vehicle through the Trader’s App so that the trader may be able to book an appointment with you.
Personal Information conveyed to Traders- After the valuation on the vehicle is completed, the customer is contacted by our sales team to get further information, pictures of the vehicle etc. After double checking the information, the car/vehicle is sent to the Trader’s App. From here the lead is available for the Traders to purchase. At this stage, the Traders are only able to view the pictures of the car and other details of the vehicle including price and vehicle specification. It is only after a Trader purchases the lead, that other personal information relating to the Customer is shared with the Trader which includes name, telephone number, e-mail address etc. This information is shared so that the Trader may be able to book an appointment with the Customer.
Personal Information used by us if we are purchasing your vehicle- There might be instances where iCashCars may buy your vehicle itself instead of sending it to the Trader’s App. Once you get an online valuation and consent to receiving a call back from us, you will be contacted by our sales team representative to collect further information and pictures of the car. For cars that we may be interested in buying ourselves, a physical on-site inspection of the car is then carried out by our On-Site inspectors. We always carry out a physical inspection of the Car before we agree to buy it. After inspection, we may offer to buy your car at a given price (the “Price”) and if you agree to the Price, we may proceed to buy your Car for which you would have to provide us with additional information that is necessary in order to complete the contract for sale of the Car.
What if you cannot or will not provide us with your personal information:
If you are a Seller/Customer, it is a requirement for you to provide us with your name, contact details & postcode for the purpose of us providing you with your valuation. If you wish to sell your vehicle to us or to the Traders registered on our Trader’s Portal through our App, it is a contractual requirement for you to provide us with certain information, namely your name, address, email address, vehicle registration details and bank account information, and other proofs we may request to satisfy our contract.
If you do not provide us with information required to obtain a valuation or to enter into contract with us/the Traders to sell your vehicle, we will be unable to provide you with our Services.
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 optimized sites, we may receive information about yourlocation 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 personalized content.
Legal Basis for processing this information:
- Legitimate interest
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.
Administration, Development and Monitoring of the Website and Services:
To administer, maintain, develop and improve our Website and services, we use your contact details and details of your activity on the Website and your interactions with us.
Legal Basis for processing this information:
- Legitimate Interest
We will use your contact details such as name, telephone number, email address, postcode and details of your activity on the Website and your interactions with us in order 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.
- provide customers/sellers 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).
- provide a user-friendly online search experience. This includes the use of website analytics tools as described further in our Cookies Policy.
- identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.
The Legal Basis we rely on for processing your information
Under data protection laws, we are required to have a legal basis to process your personal information. We have set out below the legal bases we rely on:
- Contract : To perform a contract entered into with the Customers/Sellers and fulfill our contractual obligations to them or to take steps at their request prior to entering into a contract. We also need to process personal data relating to the Traders who are seeking to register on the Website and subsequently to the Trader’s Portal for us to provide them with the requested services which include managing their account and providing service updates and our support services.
- 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 the Traders (i.e. where you provide information regarding the sale of your vehicle) or where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers). For further information regarding consent please see below.
- Legal Obligation : Where processing is necessary to comply with our legal or statutory obligations. This may include co-operating with the police in relation to their investigations.
- Legitimate interest : Where necessary for our legitimate interests or those of a third party. We rely on this basis in order to monitor and improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, to personalize content provided to you, to deal with enquiries and complaints, undertake market research and inform our general marketing, to run our business and maintain the security of our Website and services for you 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 Traders.
Where you have given consent for iCashCars to process your personal data, you may withdraw consent at any time by emailing [email protected] 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 of such consent.
If you have given consent for your details to be passed to the Traders registered with iCashCars or other third party, your data may already have been used by them to respond to your request before we can take action pursuant to 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:
iCashCars will not pass on your personal data to third parties except as set out in this Notice 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 the Traders registered with the iCashCars Trader’s Portal to enable them to provide you with the services that you have requested or consented to via the Website or the Apps. If you have queries or require more information on how these third parties use information, please read their privacy policies or contact them.
- We may send your information to the Driver and Vehicle Licensing Agency (the “DVLA”).
- 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 European Economic Area (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 with a third party 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 iCashCars may disclose your personal data to the prospective seller or buyer of such business or assets.
- 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 processor on our behalf.
Where we store your personal data:
iCashCars will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy. All information you provide to us is stored securely within the UK, and not transferred outside the UK unless specifically detailed in this Policy.
Payment card information, details you provide when requesting Trader or other third party services through the Website, is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the UK or the EEA in accordance with their privacy policies.
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.
iCashCars uses strict procedures and security features designed to prevent any unauthorized access to your data that we hold.
How long do we keep your data
ICashCars will process personal data for as long as necessary to fulfill 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 we will retain your data for as long as your account is active and a period after your account is closed to enable us to satisfy our legal, accounting and reporting requirements.
In some circumstances you can ask us to delete your data: for further information, please see below under the section titled the “ Right to be forgotten/Erasure”.
In some circumstances we may anonymize 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
Under the UK data protection law, you have the following rights:
- Erasure/Right to be forgotten
- Restrict processing
- Object to processing
Some of these rights may not always apply. You can read more about your rights below.
You may be able to exercise the following rights:
- Right of access – you have the right to request a copy of the information we hold about you free of charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information. iCashCars would respond to the request within a month of the request and in case, we require more time to process your request, the extension would be sought in writing explaining the reason/s for seeking such extension. In the event that iCashCars refuses your request under rights of access, we will provide you with a reason for such refusal.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten/ Erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restrict processing – where certain conditions, you have a right to restrict the processing of information by us. You have the right to ask us to stop using your information where (i) the information we hold is inaccurate, (ii) we are unlawfully using your information, (iii) we no longer need to use the information, or (iv) we do not have a legitimate right to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person. Where we store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms. Where we use your data because you have given us specific, unambiguous and informed consent, you have the right to withdraw your consent at any time.
- Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organization.
- 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 the Section titled “ Complaints” below.
Opting out of receiving our communications
You can ask us to stop sending you our communications at any time by:
- Selecting the “unsubscribe” feature contained within each of our communications
- Accessing our website to update your communication preferences in our Contact Preference Centre.
- Contacting our Customer Service Team by emailing us at [email protected]
If you wish to make a complaint about how your personal data is being processed by iCashCars (or third parties as described above), or how your complaint has been handled in the first instance, please email your concerns to [email protected] .
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 available at www.ico.org.uk.
Last updated on: 01/03/2021