webuyanycar privacy policy

Introduction

We are committed to protecting and respecting your privacy.

Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

For the purpose of UK data protection laws, the data controller is We Buy Any Car Limited of Form 2, 18 Bartley Wood Business Park, Hook, RG27 9XA, with the ICO registration number Z972834X.

Requests, or queries regarding this policy can be sent to complianceadvice@webuyanycar.com.

Data protection principles

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:

processed lawfully, fairly and in a transparent manner,
processed for specified, explicit and legitimate purposes,
adequate, relevant and limited to what is necessary,
accurate and kept up-to-date,
kept for no longer than is necessary, and
processed in a manner than ensures appropriate security.

Information you give to us

We may collect, use, store and transfer different kinds of personal information about you, including:

Identity Data, such as your name, marital status, title, 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, credit history (where payments are made to us), 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 organisation you represent, that organisation’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

‘Special category’ data

Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as ‘special category’ data.

During the course of dealing with you, we do not expect to collect any ‘special category’ data about you.

How we collect your personal information

We may obtain personal information by directly interacting with you, such as:

when you use the valuation tool or appointment booking tool available on our website,
entering into an agreement with us to sell your vehicle,
participate with our social media team through an online platform,
enter a competition, promotion or survey organised by us, or otherwise providing us with feedback,
corresponding 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 recognising 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.

For a full list of cookies used on our website please click here.

We may also collect personal information about you from third parties or publicly available sources, including;

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 non-compliance with the terms of our contract.
Providers of credit verification, anti-fraud and anti money-laundering verification services.

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,
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.

We will only use ‘special category’ information where the law allows us to do so.

Purposes for which we will use your personal information

We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will use the information you give to us	Legal basis
When you obtain a valuation from us, you provide your name, postcode & contact details	It is necessary for your and our legitimate interest to provide this information, to enable us to provide our service to you. Your postcode is used so we can identify your local branch; your contact details so we can communicate with you regarding the service you have requested; your name so we can personalise our contact with you.
To purchase your vehicle and, if accepted, to take possession of your vehicle and deliver the payment to you and/or your finance provider	It will be necessary for the performance of the contract between you and us
Where you are acting as a representative of an organisation, to process the organisations instructions and, if accepted, to provide our services to your organisation	It will be necessary for our legitimate business interests, namely to with a view to providing our service to your organisation, and for performance of contract where a sale is agreed.
To record the transfer of ownership of your vehicle with the DVLA via DVLA’s online portal	It will be necessary for the performance of the contract between you and us
To obtain further information about you and/or your organisation	It will be necessary for our legitimate business interests, namely to ensure we are fully aware of all issues relating to our services we are providing, and to the performance of our contract.
To validate information to satisfy our contract using publicly available information on websites such as Companies House. For example, confirming of business/asset ownership for the purpose of due diligence, validating suspicions an individual is not acting in accordance with the terms of our contract, or carrying out credit reference checks, credit score assessments, anti-fraud or anti-money laundering checks.	It will be necessary for our legitimate business interests, namely to ensure we are fully aware of all issues relating to our services we are providing, to the performance of our contract, and to satisfy legal and regulatory obligations.
Post-Sale contact where issues have been identified in accordance with our contract	It will be necessary for our legitimate business interests, and in accordance with our contract
Where you have contacted us with a query or concern via our Customer Service Team	It will be necessary for our legitimate business interest to enable us to address your query.
To notify you about changes to our website terms, our terms of sale or this privacy policy	It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions
To administer our website 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, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you	It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website. For this purpose, strictly essential cookies & local storage will be set onto your device when you visit our website. This enables us (for example) recognise you as a returning user by displaying your latest valuation, or maintain continuity in the case of a connection issue. Non essential cookies are only placed on your device with your consent. Some of these are used to (for example) display our adverts to you when you leave our website; to test versions of our website, or help understand how you use our website.
To enable you to participate in a prize draw, competition or complete a survey	It will be necessary for our legitimate business interests, namely to study how customers use our service, to develop them and help grow our business
To provide you with significant updates or special offers concerning your vehicle.	It will be necessary for us to provide you with these as legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive as part of our service (until you tell us you no longer wish to receive them)

We will only use your personal information for the purpose(s) 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What if you cannot or will not provide us with your personal information

It is a requirement for you to provide use 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, 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 to sell your vehicle, we will be unable to provide you with our service.

Disclosure of your information

We may share your personal information with the parties set out below:

the DVLA,
other personnel within your organisation, or any other organisation that is party to or otherwise has a legitimate interest in the agreement between us and your organisation,
third party service providers who support the operation of our business, such as providers of IT and system administration services, credit reference agencies and providers of anti-fraud and anti-money laundering verification services.
our professional advisers (including solicitors, bankers, auditors and insurers),
HM Revenue & Customs, the Information Commissioner’s Office, Trading Standards, Law enforcement, regulators and other authorities who require reporting of processing activities in certain circumstances,
analytics and search engine providers that assist us in the improvement and optimisation of our website.
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 information in the same way as set out in this policy.

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

Where we store your personal information

All information you provide to us is stored on our secure servers in the United Kingdom.

We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:

PCI DSS standards. We never request or hold your credit card or debit card details. Where you need to make a payment to a finance company using your credit card, we use the secure WorldPay portal which is fully compliant with PCI DSS standards. Our systems do not record any of the information entered into this portal.
Building entry controls & secure storage. Our data is held at a Tier II data centre with secure access controlled via 24 hr security, biometric access, internal & external CCTV & security breach alarms. Our Central Support team operate in a building with secure access & alarmed entry controlled by allocated swipe card access internal & external CCTV, with visitors access logged via reception, & escorted entry once in the building.
Secure lockable desks and cupboards. Where documents containing personal information are in paper form for an interim period, they are stored in secure desks and cupboards.
Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
Firewalls and Encryption. We use up-to-date and industry-standard firewall and encryption software technology.
Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection and safeguards are afforded to it in accordance with UK privacy laws.

If you have questions regarding the security of your data when transferred overseas, please let us know and we will endeavour to advise what steps are taken to protect your data when stored overseas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; 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.

How long we will store your personal information

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

Legal basis	Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us	We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject	We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests	We will use/store your data as long as it is necessary.
Where we use/store your data because you have given us your specific, informed and unambiguous consent	We will use/store your data until you ask us to stop (how to withdraw consent or opt out is detailed further on in this policy)

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

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

Your right to be informed of how we intend to use your information is detailed in this policy, notices on our website, and in our contracts should you choose to sell your vehicle to us.
You have a right to access 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.
You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
You have the right to ask us to stop using your information where: (i) the information we hold about you 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 reason 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.
You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
Where we use/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/storing 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/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
You have the right to object to us using/storing your information for the purpose of contacting you regarding your valuation.

If you wish to exercise any of your legal rights, please contact our Customer Service Team by writing to the address at the top of this policy, or by emailing us at complianceadvice@webuyanycar.com.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Opting out of receiving our communications

Communications can be stopped at any time by:

Clicking the 'Unsubscribe' link contained within any email.
Replying STOP to any SMS.
Navigating to our Contact preference centre to update your preference.

Alternative routes to unsubscribe include:

Emailing unsubscribe@webuyanycar.com, this will unsubscribe the email address you have used to send the request.
Emailing our Customer Service Team at talktous@webuyanycar.com.

Snoozing communications

If you choose to snooze, we will pause communications for this duration.

Once the snooze period ends, we will restore your subscription.

You may modify or cancel the snooze at any time.

Automated decision-making

We do not use automated decision-making processes using, or in respect of, personal data.

Third party links

Our website may include 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.

Call Recording

Calls to and from our branches are recorded for training & monitoring purposes. This is to ensure that our staff provide our customers with good customer service, in accordance with company policy and practice. Recordings are held for a limited period of time to fulfil this purpose before being erased.

Cinch Privacy Notice

Our sister company Cinch Cars Limited (cinch.co.uk) can help you find and buy cars through approved dealers. If you’ve ticked the box to say you are interested, we’ll provide cinch your name, email, mobile number, and postcode. We’ll also supply them with details regarding your valuation including the Make, Model, Fuel Type, and the value of your vehicle. Cinch will contact you by email and/or text with updates about their service, vehicle recommendations, and ways to make buying and owning cars a breeze. Cinch will be the data controller for this data, you can find out how they use it at cinch.co.uk/privacy.

If you want to update your communication preferences with cinch, access, correct or erase the data that they hold about you, or request any of your other legal rights in relation to it, you can contact cinch directly through their website cinch.co.uk, using the links in any communication sent to you by cinch, or by emailing DPO-Office@cinch.co.uk.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website.

Contact

If you have any questions or requests regarding this policy, please contact us at complianceadvice@webuyanycar.com.

Our Data Protection Officer can be contacted at DPO-Office@bca.com.

Last updated 28/09/2021