We are Carhuna Limited (“Carhuna”, “we”. “us”, “our”). Carhuna is a company registered in England and Wales (registration number 14037816) with a registered address at 22 Wycombe End, Beaconsfield, Buckinghamshire, United Kingdom, HP9 1NB.
- 1. IMPORTANT INFORMATION AND WHO WE ARE
- 2. THE DATA WE COLLECT ABOUT YOU
- 3. HOW IS YOUR PERSONAL DATA COLLECTED?
- 4. HOW WE USE YOUR PERSONAL DATA
- 5. DISCLOSURES OF YOUR PERSONAL DATA
- 6. INTERNATIONAL TRANSFERS
- 7. DATA SECURITY
- 8. DATA RETENTION
- 9. YOUR LEGAL RIGHTS
- 10. GLOSSARY
1.Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Carhuna Limited is the controller and responsible for your personal data.
Full name of legal entity: Carhuna Limited
Email address: firstname.lastname@example.org
Postal address: 22 Wycombe End, Beaconsfield, Buckinghamshire, United Kingdom, HP9 1NB
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to answer questions about our data usage and to deal with any concerns before you approach the ICO, so we would encourage you to contact us in the first instance.
The Platform may include links to third-party websites, documents plug-ins or applications, including the websites of persons or companies selling vehicles and automobilia on our Platform or other resources providing information about products listed for sale. 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 information sources and, specifically, we do not vet or review links and third-party content provided by sellers or any user using the Platform’s messaging and communications functionality. We are not responsible for the content of third-party sites or their use of your data. When you use these third party links, we encourage you to ensure that you understand how those third parties will use your data, including by reviewing the privacy information made available by those third parties.
2.The data we collect about you
Personal data means any information about a living individual from which that person can be identified (either in isolation, or in combination with other information already held by anyone obtaining the personal data). It does not include data about a living individual where the recipient of the information cannot identify that individual, either because of the nature of the data or because it has been modified to render it permanently anonymous.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not itself personal data in law, as once aggregated this data will not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Where we are required to collect personal data by law, or need to do so under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the Platform and/or to list or allow you to bid on or purchase vehicles or other products via the Platform). In this case, we may not be able to (i) provide you with access to the Platform or to specific products or services for which the personal data is required; and/or (ii) facilitate a transaction (such as the purchase or sale of a vehicle) via the Platform. We will notify you if this is the case at the time.
3.How is your personal data collected?
We use different methods to collect data from and about you including through:
(a)Contact, Financial and Transaction Data from providers of technical, payment, electronic money and delivery services, including Stripe Payments UK, Ltd (based in the UK) or its affiliates, including Stripe Payments Europe Limited and Stripe Capital Europe, Limited, based in the Republic of Ireland.
(c)Identity and Contact Data from publicly available sources, such as Companies House, the Electoral Register or the Driver and Vehicle Licensing Agency based inside the UK, or publicly available data from the internet.
4.How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one has been set out in the table below.
|Type of data
|Lawful basis for processing
|To register you as a new customer or user
|Performance of a contract with you
|To perform services for you or your business via the Platform, including:
|To manage our relationship with you which will include:
|To enable you to partake in a prize draw, competition or complete a survey
|To administer and protect our business and improve the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, including targeted marketing based on previous bidding and browsing activity
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences and to provide services and information to third parties, including aggregating and anonymising Platform and user data and offering services and aggregated data to third parties based on that data.
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) and those of third parties (to help them understand the market for vehicles, automobilia and related goods and services
|To make suggestions and recommendations to you about vehicles, products or services that may be of interest to you, including:
|Necessary for our legitimate interests (to develop our products/services and grow our business)
|In the event of a sale, transfer, reorganisation or restructuring of our business or any part of it including by transferring personal data to a new owner of our business or any part of it as part of or in preparation for such a transaction
We strive to provide you with choices regarding certain personal data uses, particularly around communications, marketing and advertising. Your user profile provides you with options to control reminders, alerts, notifications and suggestions from us.
Subject to those preferences, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you and to offer suggestions and recommendations in relation to vehicles or other goods listed on the platform.
You will receive marketing communications from Carhuna if you have requested information from us or registered an account on the Platform and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. However, we may aggregate and anonymise your data together with data from other users of the Platform in order to generate insights and information which we may share with third parties to help them improve and develop their businesses.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase or other transaction carried out via the Platform.
A cookie is a small file of letters and numbers that we store on your device with your agreement. Cookies contain information that is transferred to your device’s hard drive or other storage media.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Cookie Title Cookie Name
|Carhuna Feature Suppression
|Functionality cookie: Carhuna feature suppression cookie – enables features on the Platform to be toggled on or off
|Analytical and functionality cookie: Carhuna session cookie for user sessions, [enabling us to provide a seamless experience for our users by keeping track of how you use the Platform during a visit and adjusting your user experience accordingly]
|Strictly necessary: this cookie is set in order to store whether you have accepted or rejected cookies which are not strictly necessary
|Strictly necessary: this cookie is set in order to store whether the date which you accepted or rejected cookies has expired
Stripe Payments UK, Ltd (based in the UK) or its affiliates, including Stripe Payments Europe Limited and Stripe Capital Europe, Limited, based in the Republic of Ireland, who provide payment services to Carhuna.
To deactivate the use of third party advertising cookies, you may visit the consumer page to manage the use of these types of cookies [include link to consent management solution]
You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):
Strictly essential cookiesOFF
Analytical or performance cookiesOFF
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire after [EXPIRY PERIOD].
Change of purpose
We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
To the extent that any of our external third parties are based outside the UK, any processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. However, we are legally required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We may anonymise and/or aggregate your personal data (so that it can no longer be associated with you and is no longer personal data) for research or statistical purposes, in which case we may use the non-personal data indefinitely without further notice to you.
In some circumstances you can ask us to delete your personal data: see [your legal rights] below for further information.
9.Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us using the details given at the start of this policy.
No fee usually required
You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may either (i) we charge a reasonable fee for processing your request; or (ii) refuse to comply with your request.
What we may need from you in order to give effect to a right
You may exercise rights in your personal data yourself or may ask someone else to help you exercise these on your behalf. We may need to request specific information from you to help us confirm the identity of the person making the request and/or on whose behalf the request is made. This ensures that personal data is not disclosed to any person who has no right to receive it and that rights in relation to an individual are being exercised by that individual or with their authority. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Using the Platform to exercise your rights
The Platform and your user account settings will also provide you with means to control our use of your personal data and exercise your rights. For example, you can view, correct and update your data via user account settings, and can also opt in or out of alerts, notifications and messaging as well as electronic marketing.
Legitimate Interest means the interest of Carhuna in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We are also permitted to process personal data on the basis of other people’s legitimate interests, which may include (i) your own interest in using our services and obtaining information from the Platform; (ii) the interests of other users in communicating, reaching or interacting with you in relation to vehicles, services and other goods; and (iii) the interests of third-parties in conducting, growing and managing their own businesses.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or those of any of these third parties. We do not use your personal data for activities where our interests (or those of the third party) are overridden by the impact on you, except where we have your consent to do so or where we are required or permitted to use data by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in our group or in common ownership with Carhuna, acting as joint controllers or processors, and who may provide Carhuna with marketing support, personnel, IT and system administration or other services.
External Third Parties
“YOUR LEGAL RIGHTS”
You have the right to:
Request access to your personal data (commonly known as a 'data subject access request'). This enables you to receive a copy of the information in the personal data we hold about you and to check that we are lawfully processing it. Note that much of the information we hold about you can be reviewed using your user account settings on the Platform.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Some of the information we hold about you can be updated and corrected using your user account settings on the Platform.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid legal basis for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may be able to erase certain categories of data using your user account settings on the Platform.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you wish to object to processing on this ground in your particular situation because you consider it will have a negative impact on your fundamental rights and freedoms. We are not required to stop processing data where an objection of this kind is received - we may instead explain why our legitimate interest in using your personal data is not overridden in a particular case by your rights and freedoms.
You also have the absolute right to object to processing of your personal data for direct marketing purposes without providing us with any explanation or reason.
Your user account settings will allow you to stop processing of data in certain ways – for example, by opting out of certain notifications, alerts and promotions.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of certain types of personal data to you or to a third party. Where such data exists, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to personal data which is processed via automated means, which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.