Privacy Policy
Last Updated: 28th August 2023
Introduction
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 Forest Car Company Ltd of Crown Hill, Upshire, Waltham Abbey, Essex, United Kingdom, EN9 3TF.
Data protection principles
When processing your information, we comply with the following principles of good practice. These provide that your personal information must be:
- Processed lawfully, fairly and in a transparent manner
- Adequate, relevant and limited to what is necessary
- Accurate and kept up-to-date
- Kept for no longer than is necessary
- 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 and gender
- Contact Data, such as your home address, email address and telephone numbers
- Financial Data, such as bank account details
- Document Data, such as your V5 vehicle registration document, copies of your driving licence, passport and other documents that verify your identity
- Transaction Data, including details about payments to and from you
- 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
‘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 enquiry form on our website
- Wntering into an agreement with us to sell your vehicle
- Participate with our social media pages through an online platform
- Providing us with direct 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, 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
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 you to provide this information to enable us to provide our service subject to our terms and conditions. |
| 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. We will comply with our cookie policy when processing this information |
| 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.
Where we cannot provide a service directly, we may provide your details to 3rd parties who may be able to assist you. It is important that you also review the Data Privacy Policy with these 3rd parties. All third parties we may send your details on are listed below:
- Rhino Scrap: www.rhinocarscrap.com
Otherwise, 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.
- 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 alarms.
- 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.
Unfortunately, the transmission of information via the internet is not always secure. Although we will do our best to protect your personal information (employing industry standard encryption and secure socket layers) 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 until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data) |
| 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 |
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:
- 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 info@forestcarcompany.co.uk.
Should you wish to receive no further contact from us concerning a valuation, you can request this by updating your contact preferences via our Contact Preference Centre, or emailing us at info@forestcarcompany.co.uk.
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.
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.
Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Customer Services Team by writing to the address at the top of this policy, or by emailing us at info@forestcarcompany.co.uk