Privacy Policy

Last updated: 14^th September 2020

Carcraft.co.uk is a trading name of EGFV Rix Limited.

We are authorised and regulated by the Financial Conduct Authority, firm reference number:

EGFV Rix Limited – 717254

We are registered in England and Wales, Company Number:

EGFV Rix Limited – 09693284

Our registered address is:

2^nd Floor
1 City Road East
Manchester
England
M15 4PN

We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number:

EGFV Rix Limited - ZA141548

Your privacy is important to us, and we are committed to keeping our information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.

This Privacy Statement (together with our Cookie Policy and our Website Terms and Conditions) set out the basis upon which: we will process personal information that:

• is collected from you when you apply for and/or express an interest in a product or service;
• we obtain during the provision of that product or service;
• is provided to us through carcraft.co.uk (“Website”), over the phone or through social media.

Please read this Privacy Statement carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.

By accessing, browsing or otherwise using the Website, you confirm that you have read and agree to this Privacy Statement. If you do not agree with any part of this Privacy Statement, you should not use the Website. If you are applying for one of our products or services online or by phone and do not agree with any part of this Privacy Statement, you should not continue with your application.

We may collect personal information (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information) from you in connection with a service or product provided to you by us, including:

• Your name,
• Address,
• Telephone number,
• Email address
• IP addresses

We may collect information provided in connection with the following activities:

• If you apply for or purchase any product or service from us
  
  
• Where you provide information to us on our Website, in writing, through social media, or over the phone (including via call recording)
  
  
• If you request information or assistance from us
  
  
• If you make a complaint
  
  
• Use of the features of the Website that may be offered from time to time, and may require such information in order to utilise the feature

Four lawful bases have been defined for the processing of data:

Consent

Consent to the processing of personal data for one or more specific purposes are outlined in detail within this privacy statement. However, in summary they include:

• For marketing activities

Legal Obligations

Processing is necessary in order for carcraft.co.uk to adhere with legal and regulatory obligations. These obligations include, but are not limited to:

• HM Government for money laundering and financial crime prevention;
• Financial Conduct Authority (FCA) to evidence robust system and controls;
• Information Commissioner’s Office (ICO) to evidence appropriate technical arrangements for the processing and control of data

Legitimate Interests

Processing is necessary to enable carcraft.co.uk to develop and improve product offering. Any data held for this purpose will be pseudonymised and retained only for the purpose of improving product and service offerings and will not be used for any other purpose including communicating directly to you as an individual data subject.

Depending on the continuing relationship with carcraft.co.uk, ordinarily all four legal bases for processing will apply and carcraft.co.uk will not use personal data for any other purpose than written within this Privacy Statement.

Four lawful bases have been defined for the processing of data:

Service Provision and Internal Processing

• to provide the product or service
• to confirm, update and improve our customer records
• to troubleshoot problems with the Website or mobile application, or to customise your experience on the Website or mobile application

Management of Relationship

• to manage, analyse, understand and develop your relationship with us
• to inform you about improvements to the Website
• to keep you informed of any of our other/new products and services and identify and market products and services that may be of interest to you, where you have chosen to be made aware of this

Queries/Problems

• to respond to any queries or complaints that you raise
• for training purposes and to enhance or review the service we provide or have provided to you
• to conduct statistical analysis and research (where possible using anonymised data)

Legal Obligations

• to prevent, investigate and prosecute crime, fraud and money laundering; for auditing purposes;
• if we are obliged to disclose information by reason of any law, regulation or court order;
• A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or employment to you. If you have any questions about this, please contact us on the details provided

General

• both we and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime
• to process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested;
• fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years;

Other

• to consider you for potential job opportunities where you provide us with a CV, complete an application on LinkedIn or complete a candidate registration form;
• to transfer information to any entity which may acquire rights in us;
• for any other purpose to which you agree

5. How We Might Share Your Information

The third parties with whom we may need to share personal information to help us provide services and products to you are detailed within this section.

Car Finance

Our partners including brokers, introducers and motor dealers who we work with dependent on your individual credit profile and the specific criteria determined by the lender. 

Data collected as part of a car finance application will be processed by our partners in accordance with their Privacy Policies.

Other

• Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
• Service providers who need to know the information in order to provide us or you with a product or service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, electronic signature processing, storage of customer documentation, IT services, customer services and for data analytics (using anonymised data));
• Law enforcement bodiesin order to comply with any legal obligation or court order.
• Third parties for the purpose of validating and assessing fitness and propriety in connection with any application for employment.
• Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
• co.uk business advisors,for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations

The personal information that you provide will be retained by us in accordance with applicable laws. However, in accordance with our lawful basis, data will only be retained in line with our stated policy approach and only be used for the purposes detailed, any marketing activity will only be undertaken where we have your consent, following the conclusion of your relationship or employment with Carcraft.co.uk or its subsidiaries and trading styles. Where the information is retained under our legitimate interest’s basis, personal data will be pseudonymised and held securely and will not be used to contact you directly or for marketing purposes.

Our retention policies are aligned to individual rights and freedom and any request under those rights will be met in accordance with our stated lawful bases or obligations.

Sensitive personal data includes information about an individual's health and other categories of personal information which are closely protected (e.g. criminal convictions). We do not generally process such information, unless you have voluntarily provided that information to us (for example, where you have notified us of a health issue).

You agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible we shall seek to minimise the collection and use of such sensitive personal data.

Our Privacy Statement does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in our "car search" results. Our Privacy Statement does not cover the information practices of other companies and organisations that advertise our services and that may use cookies, pixel tags and other technologies to serve and offer relevant ads. Please see section titled 'Access to Website' in our Website Terms and Conditions for further details.

Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your data sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet. If you would like to contact us, please see the section below or use our Contact Us page.

It is highly unlikely that we will target particular products at a different age group, the Website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian.

We do not knowingly collect personal information from individuals under the age of 18. Where we are able to identify that an individual under the age of 18 has used our services (e.g. the individual may have entered a date of birth into the application form) we will ensure no further processing of the individual’s data takes place except for the purpose of erasing the data.

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure, in particular:

• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
• We restrict access to personal information to Carcraft.co.uk employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.

We and the other companies processing your data for the purposes mentioned in Section 4 may from time to time need to undertake some of the processing in countries outside of the European Economic Area. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.

Our Privacy Statement applies to all of the services offered by Carcraft.co.uk and its trading names. We will keep this Privacy Statement under review and make updates from time to time. We will not reduce your rights under Privacy Statement without your explicit consent. We will post any Privacy Statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Statement changes). If you do not accept the amended Privacy Statement, you should stop using the Website; this may affect our ability to provide certain products and services to you. Please see the section regarding Your Rights for further information regarding continued processing.

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website). To view more information on what cookies we use and how we use them please review our separate Cookie Policy.

You have a number of rights under Data Protection law including:

• Right to be informed– Carcraft.co.uk provide all customers with this privacy statement to provide transparent and clear information as to arrangements for the collection, control and processing of personal data.
• Right of Access- Copies of personal data held can be requested under an access request and will be met in the 30 day legislative standard ordinarily free of charge. Any extension to these requirements will be advised on the basis of the nature of the request but will be by exception and subject to senior management scrutiny, please see contact us section for further detail.
• Right to Rectification- In the event we hold inaccurate data please advise us of the correct information and records will be updated within 72 hours and confirmation provided accordingly (Subject to satisfactory verification of your identity).
• Right to Restriction of Processing- Data processing will be restricted whilst any claim of accuracy is being contested by you, or you have challenged the legal basis or legitimate grounds for processing for a specific purpose and to establish, exercise or defend legal claim at your request.
• Right to Object- You can object to Carcraft.co.uk processing on the basis this is contrary to your rights and freedoms, any objection relating to direct marketing will be acted upon within 48 hours, other objections will be treated as a complaint and assessed against our documented legal basis.
• Right to Erasure- Commonly known as the right to be forgotten, Carcraft.co.uk will adhere to your request ordinarily within 72 hours where legal basis is solely or partially established as consent, any data required for legal, regulatory or legitimate interests maybe maintained in accordance with documented retention schedules. However our team will confirm and discuss your request to ensure your rights and freedoms are observed at all times.
• Right to Data Portability- You have the right to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in a timely manner, generally 72 hours unless evidenced to be unduly excessive or unreasonable.

You have a further right in connection with automated decisions, however this is covered in the relevant section of this statement.

Carcraft.co.uk has established robust policy and procedural requirements to enable your rights as a data subject to be adhered with, however where this is not possible for the reasons outlined we confirm the detail.

In relation to all of these rights, please write to or contact us at the address below. Please note that we will need to verify your identity.

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to lodge a complaint with a supervisory authority (i.e. the ICO) once you have tried to resolve the issue with us.

You can contact the ICO at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113

If you have any questions about this Privacy Statement, or you think we have incorrect information or you would like a copy of the information we hold about you, you may request details of personal information which we hold about you please do not hesitate to contact us via any of the below

EGFV Rix Limited
2^nd Floor
1 City Road East
Manchester
M15 4PN

Queries:
info@carcraft.co.uk

Complaints:
customercare@carcraft.co.uk