Remove My Car Limited, a
company registered in England and Wales (No. 07978223) with a registered office at:
1st Floor, Cashs Business Centre, 228 Widdrington Road, Coventry, West
Midlands, England, CV1 4PB, hereinafter referred to as ‘RMC’ or ‘We’ have created this privacy
statement (‘Statement’) in order to demonstrate our firm commitment to
the privacy of the details that You provide to us when using www.removemycar.co.uk (the ‘Site’) and the RMC Interactive Services.
Unless otherwise indicated, all
definitions used in the Service Terms shall apply to this Statement and for the
purposes of this Statement, ‘Personal Data’ shall include financial data. In this Statement, references to ‘You’ and ‘Your’ are references to the RMC User. When You use the RMC Interactive Services, You are consenting to the practices
set forth in this Statement.
We know that Your privacy is very
important to You which makes it very important to us. We aim to be as clear as
possible in this Statement in respect of Your Personal Data. This Statement
applies inter alia to Your Personal Data that We collect about You when You use
the Site, how and when it is used, how We protect it and who has access to it.
This Statement incorporates the Cookie Policy,
the Website
Terms of Use and the Service Terms
by this reference (together the ‘Agreement’).
1. YOUR
ACCEPTANCE OF THE STATEMENT
This Statement governs
Your use of the RMC Interactive Services, including any dispute concerning
privacy. By using the RMC Interactive Services, You accept this Statement in
full. You should read the Statement carefully and ensure that You understand
its effect before proceeding to use the Site and the RMC Interactive Services.
We reserve the right to modify this Statement at any time without notice by
posting the changes on this page. Your continued use of any portion of the Site
following the posting of the updated Statement will constitute Your acceptance
of the changes.
2. WHAT
INFORMATION IS COLLECTED & HOW?
A.
Personal Data (other than financial)
2.1 The Site asks You to provide various types of Personal Data
to enhance the quality of the RMC Interactive Services We can provide to You and
the more accurate the information You provide, the better We are able to
respond to Your requirements! As part of the process of using the Site and the RMC
Interactive Services, We may collect the following types of Personal Data
about You (as applicable):
- Your RMC
Valuation Information i.e. Your postcode and Vehicle registration;
- Your email and
mobile phone number for the verification process;
- Your Trade
Registration Form information;
- Your Buyer
Registration Form information;
- Your Collection
Details which includes Your title, name, address and mobile phone number,
and any additional information;
- Your Payment
Details i.e. Your bank name, account number and sort code;
- A copy of your photo
I.D. and utility bill (to satisfy SDMA Requirements);
- Your visits to
the Site and the RMC Content that You download; and,
- Your UGC that
You may upload or submit to the Site.
B. Financial
Data
2.2
Each Transaction shall take place off the Site between the RMC Seller
and RMC Buyer Member directly. For the avoidance of doubt, RMC do not take any
payments via the Site or authorise any third party payment provider to do so.
RMC do collect the RMC Seller’s Payment Details during the Acceptance Process
acting as a Data Controller (as defined by the 1998 Act) solely in order to
facilitate a smooth exchange of information during the Completion Period. As a
RMC Seller, You hereby expressly consent to RMC providing these details to the
relevant RMC Buyer Member for the sole purpose of enabling the RMC Buyer Member
to make payment of the Auction Price to the relevant RMC Buyer Member during
the Completion Period.
2.3
Except as provided here, We will not share Personal Data with any
other third parties (including our RMC Buyer Network) without Your prior
consent.
C. Other
Data
2.4 Other de-personalised data which
does not record Personal Data as such, rather information such as the date of
Your visit to the Site, the path taken, the browser used, the IP address etc is
used primarily to aid the technical administration of the Site, to better
understand how the Site is functioning for RMC Users and to draw conclusions upon demographic
information.
3. HOW IS
THE INFORMATION USED?
3.1 Your Personal Data
may need to be passed on to third party companies or service providers
(including the RMC Buyer Network) for the sole purpose of fulfilling the RMC
Interactive Services only and not for the purposes of making marketing
communications, unless You have expressly consented to this being undertaken by
a third party. You are under no
obligation to provide such Personal Data to us, however, if You choose not to,
some of the RMC Interactive Services may not be available to You.
3.2 You acknowledge
that Your Personal Data may be used by RMC to contact a RMC User by post, phone
or by electronic mail when necessary in connection with Your use of the Site
and the RMC Interactive Services. In the case of a registered RMC Trade Member
or RMC Buyer Member, RMC reserve the right to contact You in respect of a RMC
Trade Account, RMC Buyer Account, RMC Trade Membership or RMC Buyer Membership.
3.3 From time to
time, RMC may contact You by electronic mail by way of sending You one or more
of the following:
(a)
a Verification Communication;
(b)
a RMC Auction Completion Notification;
(c)
a RMC Auction Acceptance Email;
(d)
a Collection Confirmation Email;
(e)
a RMC Auction Feedback Request Email;
(f)
a Membership Confirmation Email;
(g)
a RMC Auction Bid Notification;
(h)
a RMC Auction Offer Acceptance
Email;
(i)
an invoice;
(j)
a RMC Auction Alert; or,
(k)
any other newsletter or information or offers regarding
upcoming RMC Auctions or promotions, RMC Interactive Services or customer
surveys. For example, when You choose to accept a RMC Valuation Offer, to create
and post a RMC Listing, to apply for RMC Buyer Membership or RMC Trade
Membership, You give us Your consent to do this. If You change Your mind, You
can opt out of receiving some but not all of this in accordance with this
Statement. For example, to the extent that You request the RMC Interactive
Services, You cannot opt out of receiving (a) to (j) as these are a necessary
part of receiving the RMC Interactive Services and in particular, accessing the
RMC Auction Platform. You can opt out of receiving direct marketing
communications from RMC as descried below.
3.4 Your Personal Data
is used solely by RMC (and the RMC Buyer Network to the extent necessary to
fulfil the Transaction) for the sole purpose of enabling RMC to act as a
service provider to You and is not shared with any person or company without Your
express consent.
3.5
Any Personal Data that is held with RMC shall be
retained in accordance with the Data Protection Act 1998 and related Data Protection Legislation and/ or our
retention and destruction policy culminating in its permanent deletion.
3.6 If Personal Data
has been passed to third parties with Your consent, You may need to contact
them separately if You change Your mind in relation to their use of Your Personal
Data.
OPTING OUT: If You do not wish to be
contacted by RMC in respect of future marketing communications (excluding Clause
3.3 (a) – (j) which cannot be opted out of), We will give You the opportunity to unsubscribe to the
receipt of such communications in every electronic mail communication that We
send to You. Alternatively and additionally, You can contact RMC by
sending an email to info@removemycar.co.uk with “URGENT –
UNSUBSCRIBE REQUEST” in the subject line or send Your request by post to RMC at
the contact address below.
4. WHO HAS
ACCESS TO YOUR PERSONAL DATA?
4.1 To
minimise the risk of unauthorised access to Your Personal Data, We use some of
Your Personal Data to authenticate You when using the Site and the RMC
Interactive Services e.g. the Verification Communication.
4.2 For our
daily operations, We may use the services of third parties to provide some of
our business and operational functions. Consequently, some of the RMC Interactive
Services are provided by our business partners who are part of the RMC Buyer Network
and We need to disclose Your information to them to provide You with the RMC Interactive
Services.
4.3 Disclosure of Your Personal Data
in Compliance with Laws
You should
be aware that We may release Your Personal Data when We believe it is necessary
to comply with laws or regulations, to assist law enforcement, to enforce the terms
under which You transact or communicate with or via RMC, or to protect the
rights, property or safety of RMC, RMC Users or third parties.
4.4 Transfer of Your Personal Data
outside of the EEA
From time to time, We may transfer Your Personal Data to a related
company, agent or contractor in order to improve our RMC Interactive Services
or to assist our security, credit risk or fraud protection activities. Such
companies may be located outside of the EEA and You consent to the transfer of
Your Personal Data to such companies for the purposes set out here in
accordance with this Statement and as permitted by the Data Protection
Legislation from time to time.
4.5 Transfer of Personal Data in the
Event of the Sale of Remove My Car Limited or its Assets
In the
event that Remove My Car Limited is sold or transfers some of its assets to
another party, Your Personal Data could be one of the transferred assets. If
Your Personal Data is transferred, its use will remain subject to this
Statement. Your Personal Data will be passed on to a successor in interest in
the event of a liquidation or administration of RMC.
4.6
Other Sites and their Privacy Policies and Cookie Policies
The Site may
contain links to other websites. RMC is not responsible for the privacy practices
or the content of such websites or for the privacy policies, cookie policies
and practices of other third parties, so You should be careful to read and
understand those website policies independently.
5. HOW DO
WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?
5.1 The
privacy and protection of Your Personal Data is important to us. In addition,
any RMC User statistics that We may provide to prospective partners regarding
Your usage of the RMC Interactive Services are provided in the aggregate only
and do not include any individually identifiable data.
5.2 You acknowledge that email
messages sent over the internet are not encrypted and are not secure. Despite efforts
to protect Your Personal Data, We cannot ensure or warrant the security of any Personal
Data You transmit to us, via, to, or from our Site. You accept that RMC cannot
be held liable for any breaches of confidentiality that may occur as a result
of the use of email. If there is any sensitive or confidential Personal Data which
You do not wish to communicate by email, please contact RMC by telephone or
post to arrange an alternative method of communication. You transmit all such Personal Data at Your own risk.
5.3 Once Your Personal Data is
submitted, We have security procedures in place to protect the loss, misuse and
alteration of the Personal Data under their control. 128 bit industry standard
Secure Server
Software (SSL) is used as a minimum standard which encrypts all of Your Personal
Data in respect of a Your Payment Details including Your name, and address, so
that it cannot be read as it travels over the Internet.
5.4 How long We
keep Your Personal Data collected through our Site depends on the context in
which You provide it and the purpose for which We use it. We will only retain
it for as long as is necessary for such purposes. We will keep records of any RMC
Purchasing Statements for up to six (6) years and hold any data collected to
fulfil the SMDA Requirements for three (3) years. We may send You direct
marketing communications for as long as You do not unsubscribe from receiving
the same from RMC.
5.5 You understand and acknowledge
that You have no ownership rights in Your RMC Account and that if You cancel
the same, the same will be terminated and all Your information will be deleted
from Your RMC Account and will be further deleted from any RMC archives in
accordance with Clause 5.4. Your Personal Data may continue to be retained by
the RMC Buyer Network for limited purposes only.
5.6 Telephone
calls: If You call any of the customer service telephone
numbers quoted on this Site, We may record Your call. These recordings are used
for training and quality control to ensure that We continuously monitor and improve
our customer service standards.
6. COOKIES
For information about
cookies and how they are used on this Site, please visit our Cookie Policy.
7. COMPLAINTS
OR QUERIES
RMC tries to meet
the highest standards when collecting and using Personal Data. For this reason,
We take any complaints We receive about this very seriously. We encourage You
to bring it to our attention if You think that our collection or use of Personal
Data is unfair, misleading or inappropriate. We would also welcome any
suggestions for improving our procedures. This Statement does not provide exhaustive
detail of all aspects of RMC’s collection and use of Personal Data. However, We
are happy to provide any additional information or explanation needed. Any
requests for this should be sent to the address below. If You are not happy
with the way in which Your Personal Data is being handled by RMC, You can
complain to the Information Commissioner whose details can be found at: http://www.ico.org.uk/
8. ACCESS
TO YOUR PERSONAL DATA
RMC tries to be as open as
it can be in terms of giving people access to their Personal Data. Individuals
can find out if We hold any Personal Data by making a ‘subject access request’
under the Data Protection Act 1998. If We do hold Personal Data about You, We
will let You have a copy of that Personal Data. To make a request to RMC for
any Personal Data that We may hold, You need to put the request in writing
addressing it to the address provided below. They may be an administrative
charge applied in accordance with the applicable legislation.
9.
HOW TO CONTACT US
Requests for
information about our Statement or a ‘subject access request’ can be emailed to
info@removemycar.co.uk or by writing
to:
Remove My Car Limited
(Internal
Compliance Department)
1st Floor
Cashs Business Centre
228 Widdrington Road
Coventry
West Midlands
England
CV1 4PB
10. CHANGES
TO THIS STATEMENT
We keep our
Statement under regular review. This Statement was last updated on 18 December
2013.