Privacy Policy

In total, we collect the following personal data:

4.1 Personal data you provide when using our Services or creating a Motors account

• When you sign up for a My Garage account or otherwise express an interest to buy or sell a vehicle using the Site, we collect your email address, full name, postal address, postcode, mobile number and email preferences.
• If you are a dealer, we also collect information such as, VAT Number, company number, names of directors, owners or partners of the business and driver license number when you enter into a contract with us or through dealer tools or products when using our Services.
• Data regarding ads, feature purchases, or other data that you provide in a transaction.
• Content that you share with other Users through our messaging and chat tools.
• Financial information (e.g. direct debit information) in connection with a transaction via a third party payment provider or otherwise.
• In some cases: age, gender, interests and preferences.
• You may provide us with additional information through a web form or by updating or adding information to your Motors account, by participating in enquiries, dispute resolution, customer service calls, or if you contact us for any other reason regarding our Services.
• Other data that we are required or entitled by applicable law to collect and process or that we need for your authentication or identification, or for the verification of the data we collect.

4.2 Personal data we collect automatically when you use our Services or create a Motors account

• Data that is generated as part of one of your transactions (e.g. feature purchases) or that is linked to your Motors’ account as a result of a transaction in which you are involved, such as transaction amounts, and the time and location of transactions.
• Data that is generated through your other actions when you use our Services and which is linked to your Motors account, e.g. when you contact a dealer to express an interest in or purchase a vehicle.
• Data regarding all other interactions with our Services, your advertising preferences, and your communications with us.
• Computer and connection information, such as statistics regarding your use of services from Motors, information on data traffic to and from websites, referral URL, ad data, your IP address, your access times, your browser history data, your language settings and your weblog information.

4.3 Personal data we collect in connection with the use of cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data while you use our Services. We collect this data from the devices (including mobile devices) that you use our Services with. The data collected includes the following usage- and device-related information:

• Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content.
• Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.
• Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).
• The IP address from which your device accesses the Services.
• Location data, including the location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu.

For more information about our use of these technologies and your choices, see Cookies & similar technologies.

4.4 Personal data from other sources

We collect personal data about you from other sources and third parties to the extent permitted by applicable law.

In particular, this includes the following data:

• Data from credit agencies or bureaus (e.g. credit reports/checks)
• Data from data providers (e.g. demographic, interest-based and online advertising related data)
• Data about you from other members of the corporate group.

We combine or connect the personal data we collect from you with data from these other sources. Where personal data is disclosed to us by third parties, we take steps to confirm that the information has been collected with your consent (where required by law) and/or that these third parties are otherwise legally permitted to disclose your personal data to us.

4.5 Social network data you share with us

• You may be able to use social networks to sign in to your account or link your account with a social network. These social networks may automatically provide us with access to certain personal data they have stored about you (e.g. content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.). You can determine the personal data that we can access through the privacy settings of each social network.
• We may also use plug-ins or other technologies from various social networks. If you click on a link displayed through a social network plug-in, you voluntarily connect to that social network.

Below you will find a summary of the purposes for which we process your personal data, including the categories of recipients to whom we transmit personal data for the purposes stated, sorted by legal basis:

5.1 We process your personal data in order to fulfil our contract with you and to provide you with our Services. This includes the following purposes:

• Processing of data relating to you or your company for the purpose of entering into a contract with you and executing it.
• Provision of our Services, including but not limited to enabling requests for an appointment to view, test drive or purchase a vehicle, enabling transactions with other users, consumers, dealers (“Users”) (including the transmission of your personal data to other Users where necessary to perform the transaction, including in cases of terminated, failed or subsequently voided transactions), providing and enhancing features such as ratings and Motors account management, displaying a location with your listing via Google Maps (for more information see the Google Privacy Notice), providing other services you may use (as described in connection with such services), and ensuring the functionality of our Services. In connection with the provision of our Services, we will send you notifications relating to the execution of transactions and the use of our Services in accordance with the communication preferences in your Motors account.
• Solution of problems with your Motors account, arbitration of disputes, providing other services within the scope of customer service as well as enforcement of fee claims. For these purposes, we may contact you via email, telephone, SMS/text messages, push notification on your mobile device or by postal mail.
• Processing of general location data (such as IP address or postcode) in order to provide you with location-based services (such as radius search and other content that is personalized on the basis of your general location data).
• Enforcement of our Terms of Use or terms and conditions applicable to dealers, this User Privacy Notice and other rules and policies.
• Publication and promotion of your listings and related content on the websites or in the applications, services and tools of other corporate group members, members of the partner sites or cooperating third party operators of websites, applications, services and tools. When we share the content of your listings and any related personal data with third parties, we do so only on the basis of an agreement that limits the use of such personal data by the third party to the purposes necessary to fulfil its contractual obligations to us. Third party providers are contractually obliged to take appropriate security measures with regard to this data. Third party providers are strictly forbidden to pass on personal data contained in your listings to other third parties.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described in section 5.1:

• Other Users
• Corporate group members
• Third party service providers
• Payment service providers
• External operators of websites, applications, services and tools

5.2 We process your personal data in order to comply with legal obligations to which we are subject. This includes the following purposes:

• Participation in proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.
• Prevention, detection and mitigation of illegal activities (e.g. fraud, money laundering and terrorist financing).
• Ensuring the information security of our Services.
• Retention and storage of your personal data to comply with specific legal retention requirements (for more information on Motors’ storage of your data, see Storage duration and erasure).

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described in section 5.2:

• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies.
• Third party service providers
• Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to us.
• Credit agencies bureaus or associations, if required by applicable law (e.g. information on payment delays, payment defaults or other irregularities that may be relevant to your credit report).
• Corporate group members

5.3 We process your personal data in order to protect your vital interests or the vital interests of another natural person. This includes the following purposes:

• Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described in section 5.3:

• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
• Third parties who are involved in judicial proceedings.
• Corporate members
• Third party service providers

5.4 We process your personal data where necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. In order to reconcile our legitimate interests with your rights, we have introduced appropriate control mechanisms. On this basis, we process your data for the following purposes:

• Maintain audit logs of communications between us and buyers and sellers of vehicles via the Site. This is to assist in dispute resolution, for customer services purposes, quality monitoring purposes and for us to demonstrate the value of our service to our clients.
• Participation in disputes, proceedings (including judicial proceedings) conducted by courts, law enforcement agencies, government agencies or public authorities, intergovernmental or supranational bodies, in particular for the purpose of detecting, investigating and prosecuting illegal acts, unless there is a statutory obligation to this effect or we have an obligation to do so under section 5.2, and we may legitimately assume that the disclosure of the data is necessary to avert imminent disadvantages or to report a suspicion of an illegal act. In such cases, we will only disclose what we believe is necessary, such as your name, city, postcode, telephone number, email address, user ID history, IP address, device ID, fraud complaints, offers and listing history.
• Protection of the legitimate interests of third parties in connection with disputes, unless there is a statutory obligation to this effect, if we may legitimately assume that it is necessary to disclose the data to such third parties in order to avert imminent disadvantages.
• Prevention, detection, mitigation and investigation of fraud, data and security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks (e.g. through the use of captchas or the telephone number stored in your Motors account for two-factor authentication), unless there is a statutory obligation to this effect.
• Monitoring and improvement of the information security of our Services, unless there is a statutory obligation to this effect.
• Performance of identity checks, creditworthiness and other financial standing checks, evaluation of applications and comparison of information for accuracy and verification purposes.
• Provision of functions for Users that make the processing of transactions easier or more convenient (e.g. overview of sent or received enquiries).
• Analysis and improvement of the Services from corporate group members, e.g. by reviewing information from Users about blocked or crashed pages in order to identify and solve problems and to provide you with an improved user experience, including as part of product development.
• Analysis of telephone conversations with our customer service.
• Advertisements by postal mail (according to your communication preferences in your Motors account).
• To the extent permitted by applicable law without your prior consent, we will use your personal data for marketing analysis and to provide you with promotional update communications by email, post, telephone calls about our products and/ or services and to offer you coupons, discounts and special offers, to conduct opinion polls and surveys. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to privacy@motors.co.uk. For technical reasons, the implementation of your unsubscription may take a few days.
• For Users outside the European Economic Area (EEA): Personalisation, measurement and improvement of our and third-party advertisements in our online offerings, the online offerings of other corporate group members or third parties.
• Customisation of page content to display the items and services you may like based on the actions you take.
• Evaluation of the quality and success of our email marketing campaigns (e.g. through analysis of opening and click rates).
• Offering of partner and bonus programs.
• Provision of shared content and services (such as registration for services, transaction processing, propositions about services that we jointly offer with other corporate group members and customer service) with corporate group members.
• Initiation, preparation and execution of a company acquisition, e.g. in the event of a merger with another company or takeover by another company. If such an event occurs, we will require the merged entity to comply with this User Privacy Notice with respect to your personal data. Should your personal data be processed for any purpose not specified in this User Privacy Notice, you will be informed in advance of the processing of your data for this new purpose.
• Assertion of or defence against legal claims, including those asserted by one Motors user against another Motors user.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described in section 5.4:

• Corporate group members
• Third party service providers
• Other Users
• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
• Third parties who are involved in judicial proceedings
• Credit agencies or bureaus (e.g. information about payment delays, payment defaults, or other irregularities that may be relevant to your credit report)
• Other companies in the context of a company acquisition

Information about your right to object to processing based on our legitimate interests can be found below under Rights as a data subject and, with regard to the use of cookies and similar technologies, below under Cookies & similar technologies.

5.5 With your consent, we process your personal data for the following purposes:

• For Users within the European Economic Area (EEA): Personalisation, measurement and improvement of our and third party advertisements in our online offerings, the online offerings of other corporate group members or third parties such as our partner sites.
• Marketing communications by telephone or electronic mail (such as email or SMS), including communications by other corporate group members or by third parties, unless these communications are permitted without your consent under applicable law.
• Processing of your exact location data to provide location-based services.
• Processing of your personal data on the basis of your consent, which you have given so that we or third parties (such as our partner sites) can enable you to use certain services or make them available to you.

You can find information about your right to withdraw your consent below under Rights as a data subject and information with regard to the use of cookies and similar technologies below under Cookies & similar technologies.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Corporate group members
• Third party service providers, including partner sites
• Other third parties with whom we partner to offer you specific services (as described at the collection of the respective user consent)
• Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions and customer support). These third party financial institution partners will use your personal data to send you marketing communications only if you have requested their services.

5.6 Data Sharing between Corporate Group Members

As set out above under “Personal data from other sources,” we also receive access to personal data about you from other corporate group members. This enables us, in particular, to provide you, with your consent where legally required, with information about products and services, which we believe might interest you, and improve our products, services, content, and advertising by analysing your use of the services of other corporate group members, in particular through the matching of certain data (e.g. cookie IDs). Furthermore, this allows us to better prevent, detect, mitigate and investigate fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks. We will also grant access to personal data about you to other corporate group members for the aforementioned purposes. To the extent that other corporate group members have access to your personal data, they will follow practices that are at least as restrictive as the practices described in this User Privacy Notice.

5.7 Automated decision-making

We may use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless such a decision is necessary for entering into, or the performance of, a contract with you, we have obtained your consent, or we are required by applicable law to use such technology. You will find information on your right to object to this processing of your data below under Rights as a data subject.

We will only transfer your personal data to third countries, i.e. countries outside the EEA and the UK on the basis of appropriate safeguards.

Motors provides the necessary safeguards, e.g. through the conclusion of standard data protection clauses (2010/87/EU, 2001/497/EC or 2004/915/EC) with the recipients, or through other measures provided for by law. A copy of the documentation of the measures taken by us is available on request.

The specific retention periods for personal data are documented in our regional data retention guidelines. How long we retain personal data may vary depending on the Services we provide and our legal obligations under applicable national law. The following factors typically affect the retention period:

• • Necessity for the provision of our Services

This includes such things as executing the contract with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.

• • Special categories of personal data

If we store special categories of personal data, a shorter retention period is usually appropriate.

• • Consent-based processing of personal data

If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary in order to process it according to your consent.

• • Statutory, contractual or other similar obligations

Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

Your rights in detail:

• You can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.
• You have the right to obtain access to your personal data that is being processed by us. In particular, you may request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal data’s source (where they are not collected from you), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details. Your right to access may be limited by national law.
• You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• You have the right to obtain from us the erasure of personal data concerning you, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims. The right to erasure may be limited by national law.
• You have the right to obtain from us restriction of processing to the extent that
  • the accuracy of the data is disputed by you,
  • the processing is unlawful, but you oppose the erasure of the personal data,
  • we no longer need the data, but you need it to assert, exercise or defend legal claims or
  • you have objected to the processing.
• You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (“right to data portability”).
• You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or the registered office of the controller. If you are in the UK, you can direct your complaint to the Information Commissioner’s Office address at:

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

You can exercise your rights as a data subject by contacting us.

If you would like to change your preferences regarding Motors notifications (including marketing communications), you can do so at any time in My Garage. If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received or by contacting us. For technical reasons, the implementation may take a few days. For information on how to manage your cookie and similar technology preferences, see the next section Cookies & similar technologies.

Our cookies and similar technologies have different functions:

• They may be technically necessary for the provision of our Services.
• They help us optimise our Services technically (e.g. monitoring of error messages and loading times).
• They help us improve your user experience (e.g. save font size and form data entered).
• They allow us to show you more relevant advertisements.

You are free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings. In addition, you can decide whether we may use cookies and similar technologies to show you personalised advertisements:

• Users in the European Economic Area (EEA) can use Advertising and related preferences to determine to what extent they consent to the processing of their personal data for advertising purposes via cookies (and similar technologies).
• You can find information about third-party cookies (and similar technologies) related to advertising and how to prevent their use on the following websites:
  • www.youronlinechoices.eu
  • www.aboutads.info/choices (only available in English)
  • www.networkadvertising.org/choices (only available in English).

If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means that these advertisements will not be personalised for you using first-party or third-party cookies, web beacons, or similar technologies.

What happens when you share your personal data on our sites or applications?

Other Users have access to the information you share on Motors or disclose to other Users. For example, other Users can see your items for sale.

Your responsibilities over information you receive through Motors

When you correspond with another user and you receive personal data of the other user (such as name, email address, contact information, shipping and billing information) you are, independent from us, the controller of such data and responsible for any processing.

Unless you act for purely personal purposes, we recommend that you explain your data processing activities in your own privacy notice and protect the privacy of other Users. As a seller, you must in any case comply with the applicable data protection laws and in particular protect the rights of other Users as data subjects, e.g. give them the opportunity to access the personal data collected by you and demand that it be erased.

You may use the personal data that you have access to only for Motors transaction-related purposes, or for other Services offered through Motors (such as fraud complaints, and member-to-member communications), and for purposes expressly consented by the user to whom the data relates. Using personal data of other Users that you have access to for any other purpose constitutes a violation of our Terms of Use.

Personal data relating to third parties

If you provide us with personal data relating to another person, you must obtain the consent of this person or the disclosure of the data to us must be otherwise legally permissible. You must inform the other person of how we process personal data in accordance with our User Privacy Notice.

Are you obliged to provide your personal data to us?

Some of the personal data that you provide to us (e.g. data by which we can identify you) are required when you enter into a contract with us. The provision of any other personal data is voluntary, but may be necessary for the use of our Services, such as offer details, or contact information needed to post an ad.

Children’s Privacy

Our services are not intended for the use by children. We do not knowingly collect personal data from Users who are considered children under applicable national laws.

Staying Signed in

When you sign in to your account within the Site you stay signed in for a certain period of time. If you are using a public or shared computer, we encourage you to sign out at the end of your session. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorisation. The specific actions and account activities that you or any other user of this computer/browser may take include:

• Listing or enquiring about an ad
• Manage your ads
• View the My Motors page
• View or edit My Favourites and Saved Searches
• View the profile page
• Send member-to-member messages
• Leave a Rating and/or a Review

If you attempt to change your password, User ID, update any other account information or attempt other account activity beyond those listed above, you may be required to enter your password.

You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal data.