Auto Trader is a UK digital automotive marketplace that offers a vehicle buying and selling process for private individuals and trade customers. To provide retailers with the full range of Auto Trader products and services, a retailer may provide us with, and we may collect and process, certain personal information about the retailer (where the retailer is a sole trader/partner) or about people employed or engaged by that retailer. We will collect and process information about people who:

• communicate with us (by phone, SMS, email, in letters, social media and in person);
• are registered to use our trade portal (Portal);
• use our trade pay as you go advertising service (PayGo);
• use our products and services including on behalf of a retailer or otherwise act on behalf of a retailer in its dealings with us; and/or
• whose information is provided to us by, or on behalf of, a retailer.

This Notice provides details regarding the information that we hold and use relating to such individuals (users/ you/ your). Personal data (or personal information as referred to in this Notice) is information that relates to an identified or identifiable information. Some of the categories of information listed in this Notice won't relate to you individually but might instead relate to the retailer that you represent. In addition, some categories of information may not apply depending on the nature of the products and services which Auto Trader provides to you or the retailer that you represent.

We may also collect and process personal information about you when you use the Auto Trader website at www.autotrader.co.uk (Website) or any of the other Auto Trader platforms including mobile and tablet and the Auto Trader app (Platforms). References in this Notice to Site include the Website and Platforms. We have a separate privacy notice for the Site and you should also review this Website Notice for information regarding the personal information that we collect and process through the use of the Site.

Our Privacy Promise

Auto Trader Limited (Auto Trader/ we/ us/ our) is committed to protecting your personal information, being transparent about the personal data we hold and wherever possible giving you control over how we use it.

It's important that you read this Notice as it explains:

• What personal information we collect about you. The information set out below may not all constitute your personal information ;
• Why we collect and use your personal information and the legal bases we rely on;
• Who we disclose your personal information to;
• Where we store your personal information;
• How long we keep your personal information; and
• Your rights regarding the personal information you provide to us.

Amendments and updates to this Notice may be made from time to time. Any revisions will be posted on the Portal and/or the Site so you will always be aware of the information we collect and process. Please review this page regularly so that you are aware of any changes. We will also give retailers at least 15 days' notice of any changes to this Notice, by email or other durable medium, in accordance with clause 2.4 of our Main Advertising Terms and Conditions.

• 1. Who are we? Data Controller and contact details

  For the purposes of this Notice, the data controller is Auto Trader Limited (registered in England and Wales under company registration number 03909628) and whose registered office address is at Auto Trader Limited, 4th Floor, 1 Tony Wilson Place, Manchester, M15 4FN.

  References in this Notice to "Auto Trader" also apply to our sister channels on the Site, including: Commercial Trader, Auto Trader Bikes, Auto Trader Trucks, Auto Trader Plant, Auto Trader Vans, Auto Trader Farm, Auto Trader Motorhomes, Auto Trader Caravans and Prestige Cars "Top Marques".

  If you have any questions regarding the use of your personal information please:

  Email us at: dataprotection@autotrader.co.uk

  Or

  Write to us at:

  Data Protection, Auto Trader Limited, 4th Floor, 1 Tony Wilson Place, Manchester, M15 4FN.

• 2. Information collected and how we use it

  Information may be disclosed to us directly by you or we may collect this information from a third party including a retailer that you are associated with or anyone else representing that retailer and from other third parties and business partners we work with.

  Account Creation and Administration

  To create an account on the Portal or register for our PayGo service, we will collect your name, email address, mobile phone number and your chosen password. We will use your name and email address to administer your account and to send you communications about your account.

  We may also request a copy of your photographic identification (such as your passport or driving licence), facial images, ID numbers and proof of your home or trading address in order to carry out identity checks.

  Legal basis:

  • Contract
  • Consent
  • Legitimate interest

  Click here for an explanation regarding the legal basis.

  More Information

  We use your name and email address to register your account and create login details, administer your account (including managing payments) and to send you service communications and otherwise communicate with you in relation to your account. We may also use your mobile phone number to send you urgent service communications by SMS, where you have provided a mobile phone number for this purpose. You can update your details by contacting your account manager. We may share your identity data (such as your name and address) with or engage Experian Limited, 192.com Ltd, GB Group plc and/or Credas Technologies Ltd in order to verify your identity when you create an account on the Portal or otherwise register for our services. To use our PayGo service, we may ask you to provide your identity documents and facial images, along with your ID numbers and address, to Stripe Payments Europe, Ltd (“Stripe”) in order for them to verify your identity documents. Stripe's privacy notice can be found at Privacy Policy.

  Provision of Auto Trader products

  As part of the advert placement process on the Site, we will collect a name, telephone number and email address and full postal address. Within your account you can save and store vehicle details including make, model, VRM (Vehicle Registration Mark) and mileage.

  We will collect certain bank details in order to take payment for our products together with other information to administer your account.

  Legal Basis:

  • Contract
  • Consent
  • Legitimate interest
  • Legal Obligation

  Click here for an explanation regarding the legal basis.

  More Information

  In order to place an advert and comply with legal requirements, we require contact details including full postal address details for the retailer. These details are also required for invoicing purposes.

  A Vehicle Registration Mark (VRM) is required to place an advert on the Site for regulatory and security purposes. If a vehicle is registered to you, the VRM may constitute your personal data. We will not disclose the VRM within the text of an advert to any person. We will use the VRM to perform a vehicle check for all vehicles advertised on site and to provide a vehicle check on a vehicle advertised on Site at the request of a potential buyer. If the VRM is displayed in photographs within an advert then these details will be visible to Site visitors who may use them without authorisation.

  A retailer is required to supply to us bank account details in order to enable us to set up a direct debit. We retain no record of any payment card information but do hold some tokenised payment details. We use third party payment providers to manage online card payment transactions. Payment card information is collected over a secure online payment gateway provided by:

  • WorldPay - processed in accordance with their privacy policy: www.worldpay.com/uk/privacy-policy

  All payment transactions processed are encrypted. Your payment card information is used solely to process payment for your advert. We retain no record of your payment card details.

  We may use your personal information in order to enforce our contractual and legal rights (including to collect payments due to us).

  Communication with us

  When you communicate with us, you may provide personal information to us such as your name, address, contact details, organisation details (including job title and other details contained in an email signature) . We will use this in order to deal with your communication.

  Legal basis:

  • Contract
  • Consent
  • Legitimate interest

  Click here for an explanation regarding the legal basis.

  More Information

  You may provide your personal information to us for one of the following reasons:

  • To request information about advertising with Auto Trader or about any of Auto Trader's products;
  • To request support;
  • To utilise the Auto Trader products;
  • To make a complaint or enquiry;
  • To enquire about working with us whether the enquiry is made by you personally or on behalf of an organisation;
  • To register for and/or attend an event or webinar;
  • To enter a competition or prize draw that we run;
  • To respond to a survey;
  • To comment/share/post on any of our social media accounts or on our social media posts; and
  • In your social media posts that you tag us in or use any of our hashtags in.

  Chat/Text Service

  If you take part in the chat or text service to communicate with visitors to our Site (Chat Service), you may disclose personal information to such visitors while using the service such as your name and your photograph. This information will also be accessible to Auto Trader and the third party provider of the Chat Service.

  Legal Basis:

  • Consent
  • Legitimate interest

  Click here for an explanation regarding the legal basis.

  More Information

  For some of our retailers, the Chat Service is provided by a third party, Live Person Automotive and data they receive is processed in accordance with their privacy policy: www.livepersonautomotive.com/policies/privacy-policy. If the Chat Service is provided to you (or to the retailer you represent) by a different provider, please refer to the relevant Chat Service provider's privacy policy.

  All conversations and email exchanges are recorded. Any personal information that you disclose during a live chat, text or via an online form will be accessible to and processed by the Chat Service provider and the person with whom you communicate. This information is not available to or accessed by Auto Trader. Additionally, the Chat Service provider may use computer infrastructure which is situated outside of the European Economic Area (EEA) and the UK. By using the Chat Service, you acknowledge and agree that any personal information disclosed while using the Chat Service will be processed and stored by the Chat Service provider on its systems outside the EEA and the UK and protected by adequate safeguards.

  Dealer Reviews

  We offer the ability for individuals to leave reviews of retailers and for retailers to respond to those reviews (Review Service). The reviews will disclose a reviewer's name, age and location and any other personal information disclosed by a reviewer/responder.

  Legal Basis:

  • Consent
  • Legitimate interest

  Click here for an explanation regarding the legal basis.

  More Information

  Dealer reviews will show across all of the relevant retailer's advertising on the Site. All reviews are moderated and subject to our moderation rules (or those of our third party provider) and content standards which state that personal information other than name, age and location should not be disclosed.

  For some of our retailers, the Review Service is provided by a third party, Feefo Holdings Limited, and data they receive is processed in accordance with their privacy policy: www.feefo.com/en/business/privacy-policy

  Administration, development and monitoring of the Portal, our Site and products

  To administer, maintain, develop and improve the Portal, our Site and products and to monitor the security of the same, we use your contact details and details of your activity on the Portal, the Site and interactions with us such as name, telephone number, email address and postcode, details of adverts you have published, searches you have made, products you have requested, details within your account (such as name, email address and an encrypted record of your login password) information relating to your interactions with us, device location and information collected through the use of cookies on the Portal and/or the Site. For further information regarding our use of cookies and similar technologies see our Cookie Policy.

  Legal Basis:

  • Legitimate interest
  • Legal Obligation
  • Consent

  Click here for an explanation regarding the legal basis.

  More Information

  We will use your contact details such as name, telephone number, email address and postcode, details of adverts you/the retailer have published, details within your account and details of your activity on the Portal and the Site and your interactions with us in order to:

  • provide and administer the Portal, the Site and the products you/the retailer have requested;
  • manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Portal, the Site and our products.
  • provide a user friendly online experience in the Portal and on the Site. This includes the use of website analytics tools as described further in our Cookie Policy.
  • to detect and block disruptive or fraudulent use of the Portal, the Site and any scams, fraudulent, criminal or suspicious activity.

  Marketing and Business Development

  We may use your name and email address to send you marketing communications from time to time. We may also use your personal information for internal business purposes including business development.

  Legal Basis:

  • Consent
  • Legitimate interest

  Click here for an explanation regarding the legal basis.

  More Information

  We may send you marketing communications from time to time and will usually do so on the basis of legitimate interest. You have the option to unsubscribe from receiving these at any time.

  We may also use the personal information you provide for internal business records and purposes, including to analyse and develop our products and services, the Portal and the Site.

  The lawful bases we rely on for processing your information

  Under data protection laws, we are required to have a legal basis to process your personal information. We have set out below the legal bases we rely on:

  • Contract: To enter into a contract with you (where you contract with us individually e.g. as a sole trader) and fulfil our contractual obligations to you. This processing is necessary for us to provide the products you have requested including registering and managing your account, publishing your adverts and providing service updates and our support services.
  • Consent: To provide information and take actions in relation to products which you have opted-in to receive. For further information regarding consent please see below.
  • Legal Obligation: Where processing is necessary to enable us to comply with legal or regulatory requirements. This may include cooperating with the police or Trading Standards in relation to their investigations.
  • Legitimate interest: Where necessary for our legitimate interests or those of a third party. We rely on this basis in order to monitor, protect and improve the Portal, our Site, products and/or services, to manage your login and access to the Portal, to process payments and recover debts, to understand how visitors and customers use the Portal, our Site, products and/or services, undertake market research and to carry out and inform our general marketing, to run our business and maintain the security of the Portal and our Site, products and/or services for you, us and other visitors and users.

  Consent

  Where consent is required for us to process certain types of your personal information, it must be clearly given.

  Where you have given consent to us to process your personal information you may withdraw consent at any time by emailing dataprotection@autotrader.co.uk. We will cease processing your personal information based on that consent where legally required to do so, but this does not affect any processing we have undertaken at any time before withdrawal or other processing that we do where we have an alternative legal basis. We will also maintain a record of your consent withdrawal.

• 3. Disclosure of your information

  We will not pass on your personal information to third parties except as set out in this Notice or otherwise with your consent:

  We may use service providers to help us run the Portal, the Site, our products or services available on the Site , some of whom may be based outside the EEA and the UK. These third parties (including those listed below) may have access to your personal information. We require such service provides to have appropriate safeguards in place to protect your personal information:

  • We provide retailers with a call tracking product (provided by IOVOX). Retailers are provided with a tracking number that they can include within an advert on the Site. Calls to that number are tracked and, in some cases, recorded (recording can be switched off by the retailer). We provide information to the retailer regarding calls made to that number. The retailer remains the data controller of any information collected during the call and Auto Trader will not access this information.
  • In order to verify your identity, we may disclose your personal information (including your name and address) with Experian Limited, 192.com Ltd, GB Group plc and/or Credas Technologies Ltd. .
  • In order to carry out vehicle checks, we will disclose a VRM to our vehicle check provider, Experian Limited.
  • As a security measure, we use 2 factor verification when you login to your account. We send your mobile number and a code to a third party provider (IOVOX or Clickatel) who will send you a code to enable you to login.
  • For some of our retailers, the Chat Service is provided by a third party, Live Person Automotive and data they receive is processed in accordance with their privacy policy: www.livepersonautomotive.com/privacy-policy/
  • For some of our retailers, the Review Service is provided by a third party, Feefo Holdings Limited, and data they receive is processed in accordance with their privacy policy: www.feefo.com/en/business/privacy-policy

  We will also disclose personal information to a third party as follows:

  • Where we are under a duty to disclose or share your personal information with a third party in order to comply with any legal obligation.
  • Where required in order to enforce our terms and conditions and any other agreements . This includes disclosure to our debt collection agency (Credit Style Limited) to collect payment and instigate legal action on our behalf.
  • If we sell or buy any business or assets, in which case Auto Trader may disclose your personal information to the prospective seller or buyer of such business or assets.
  • We may share your personal information with our group companies.
  • We may share your personal information with the retailer you are associated with/represent and other group companies of the retailer. This may include sharing information about a user's activities on the Portal or use of our products and/or services, where we reasonably suspect such activities and/or use may be disruptive, fraudulent, suspicious or otherwise in breach of our terms.
  • We may share your personal information with other classified advertising sites, vehicle manufacturers, bike manufacturers and relevant third parties to enable us to provide you with the services and products that you have requested. In certain circumstances, vehicle manufacturers (including Ford Motor Company Limited) or bike manufacturers and other relevant third parties may subsequently transfer, process and store your personal information outside of the European Economic Area ("EEA") for their business and administration purposes. in accordance with their own privacy policies. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them. We may share any information that we collect with parties including: our legal and professional advisors (including accountants and auditors), the police, law enforcement and fraud prevention agencies, other public or private sector agencies, governmental or representative bodies and regulators (which may include HM Revenue and Customs, Trading Standards, Department for Work and Pensions, Information Commissioner's Office, Financial Conduct Authority, National Crime Agency), insurance companies, finance companies, automotive advertising companies and/or other agencies, credit reference agencies for the purposes of complying with our legal obligations, the prevention or detection of fraud and offences, and/or the apprehension or prosecution of offenders, in order to enforce our legal and contractual rights or those of a third party.
  • You acknowledge that we have a legitimate business interest in preventing the use of the Portal, our Site, our products and services in any manner that may facilitate fraudulent activity or deny consumers of their legal rights under the Consumer Protection from Unfair Trading Regulations 2008 or the Consumer Rights Act 2015. We may share any information that we collect about you or the vehicles that you advertise for sale on our platform with regulators, law enforcement, third parties or their legal representatives to the extent necessary to prevent fraud or any adverse effect to those third parties consumer rights .

  We are not responsible for any use of your personal information by these third parties except where they act as our processor.

• 4. Where we store your personal information

  Auto Trader will take all reasonable steps to ensure that your information is treated securely and in accordance with this Notice. All information you provide to us is stored securely and not transferred outside the UK or the EEA unless specifically detailed in this Notice and/or unless such transfer is otherwise permitted by data protection law.

  More Information

  We may use third party service providers who may be located outside of the EEA and the UK and/or who may store information outside of the EEA and the UK.

  In particular, payment card information and other information you provide when using a service that is provided by a third party on our behalf is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the EEA and the UK in accordance with their privacy policies.

  Where we transfer your information outside of the EEA and the UK, we will only do so in accordance with data protection law. We will ensure that safeguards are in place to provide a similar degree of protection to protect it as are provided in the UK. This may include contractual protections in place with our service providers or transferring your information to countries or parties which are recognised as providing suitable protection by the European Commission and/or the UK.

  Certain parties to whom we disclose your personal information may transfer your information outside of the EEA and the UK after we disclose it to them as part of their business and administration activities (see above, Disclosure of your information). We are not responsible for any use of your personal information by these parties except where they act as our processor. If you have queries or require more information on how these third parties use your information, including such transfers outside of the EEA and the UK, please read their privacy policies or contact them.

  Auto Trader uses strict procedures and security features designed to prevent any unauthorised access to your information that we hold.

• 5. How long do we keep your information

  Auto Trader will process personal information for as long as necessary to fulfil the purpose we collected it for, including in order to host your account, provide you with any products requested, for the purpose of legal, accounting and reporting requirements, for the prevention and detection of criminal activity, to enforce our legal and contractual rights and as long as necessary to comply with our legal and regulatory obligations.

  Where you have a login we will retain your personal information used to administer your account and login for as long as your login is live and for a period after your login is closed to enable us to satisfy our legal, accounting and reporting requirements.

  In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

• 6. Your rights as a data subject

  Under data protection law, you have the following rights in respect of any of your personal information that we hold:

  • Right of Access
  • Right of Rectification
  • Right of Erasure/Right to be forgotten
  • Right to Restrict Processing
  • Right of Portability
  • Right to Object to processing
  • Right to Complain

  These rights are not absolute and are subject to certain conditions and exemptions. These rights may therefore not always apply.

  More Information

  You may be able to exercise the following rights (subject to certain conditions and exemptions) in relation to your personal information:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct information that we hold about you that is inaccurate or incomplete.
  • Right or erasure – in certain circumstances, you can ask for the information we hold about you to be erased from our records.
  • Right to restrict processing – where certain conditions apply, you have a right to restrict the processing.
  • Right of portability – in certain circumstances, you have the right to have the information we hold about you transferred to another organisation but this only relates to personal information we hold about you.
  • Right to object – you have the right to object to certain types of processing such as direct marketing, automated processing or profiling.
  • Right to complain to the supervisory authority – you have the right to complain as outlined below.

  Please email dataprotection@autotrader.co.uk if you have any queries regarding your rights or would like to exercise any of your rights. All of the above requests will be forwarded on should there be a third party involved (as set out in this Privacy Notice) in the processing of your personal information and that third party is the controller. In particular, we are not responsible for any processing of your personal information that is carried out by the retailer that you are employed/engaged by or otherwise associated with.

• 7. Complaints

  If you wish to make a complaint about how your personal information is being processed by Auto Trader or how your complaint has been handled, we would like the opportunity to discuss this with you and try and resolve the matter. Therefore, in the first instance we would ask that you please:

  Email your concerns to: dataprotection@autotrader.co.uk

  Or

  Write to us at:

  Data Protection, Auto Trader Limited, 4th Floor, 1 Tony Wilson Place, Manchester M15 4FN.

  You also have the right to lodge a complaint directly with the UK supervisory authority which is the Information Commissioner’s Office and can be contacted via the details at www.ico.org.uk.