Privacy Policy – Online Cars Direct

Online Cars Direct Privacy Notice

1. Introduction

LJI Investments Limited (“Online Cars Direct”) is committed to protecting your privacy. This Privacy Policy sets out the basis on which any personal data is collected from you and processed by Online Cars Direct including how we protect your data.

For the purpose of the Data Protection Act 1998 and the General Data Protection Regulations 2018, the Data Controller is LJI Investments Ltd, a company registered in England and Wales under company registration number 10279804 and whose registered office address is at LJI Investments Ltd, Meryll House, 57 Worcester Road, Bromsgrove, Worcestershire, England, B61 7DN.

Revisions to the Notice will be updated here so you will always be aware of what information we collect and the legal basis for our processing.

The Privacy Notice was last updated on 22/05/2018.

2. What is personal data?

Personal data is data which relates to a living individual who can be identified directly or
indirectly either:
• From that data; or
• From that data and other information which is in our possession, or is likely to come into our possession.

3. What is our legal basis for processing your data?

The normal legal basis for us processing your data is that it is necessary for the legitimate interests of LJI Investments Ltd. We have carefully assessed these interests and balanced them with the interests of our customers to ensure fair processing e.g. processing data to facilitate the car buying journey and aftersales customer care as efficiently as possible.

If you are making a finance application another legal basis is relied upon; that it is necessary for the entering into and the performance of a contract. Upon purchasing a vehicle your personal data will be stored for up to 7 years, the legal basis being that it is a necessary for compliance with a legal obligation, as the HMRC require this for accounting purposes.

For more examples of how your personal data may be processed and the legal basis for doing so please see the separate headed section below.

4. Examples of how your personal data may be processed and the legal basis for doing so

The below are some of the reasons for processing customer data in-line with the legitimate
interests of LJI Investments Ltd (Online Cars Direct)
• Supplying goods and services to our customers;
• Improving existing products and services and developing new products and services;
• Handling customer contacts, queries, complaints or disputes;
• Understanding our customers’ behaviour, activities, preferences, and needs in order to provide a tailored service;
• Allowing our advisers to follow up our service, either by email, telephone, SMS or mail, as part of our customer care procedures;
• Promoting, marketing and advertising our products and services; and
• Sharing your data with selected third-party partners whose products and services
support and describe our sales, customers, traffic patterns and other site information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes. These statistics will include no personally identifying information. In particular circumstances we will also process and share your personal data in order to comply with a legal obligation, for example:
• Preventing, investigating and detecting crime, fraud or anti-social behaviour including
but not limited to prosecuting offenders, including working with law enforcement
agencies;Effectively handling legal claims or regulatory enforcement actions taken
against Protecting LJI Investments Ltd (Online Cars Direct) its employees and
customers, by taking appropriate legal action against third parties who have
committed criminal acts or are in breach of legal obligations;
• Protecting customers, employees and other individuals and maintaining their health and safety; and
• Complying with any other legal and regulatory obligations that may arise.
Lastly, we will process and share your data in the following ways on the condition that your consent has been given:
• Sending promotional, offers and news related communications which are relevant and tailored to you; and
• Sharing your data with third parties so that they can communicate related products and services which may be of interest to you.

5. How do we use your personal data?

A. Collected on onlinecarsdirect.uk
you will be required to supply your full name, email address, password, postcode and mobile telephone number. Your contact details are collected to enable us to contact you directly depending on one or more of the below requests. Px valuations, Finance applications or If You would like a call back, or book a
test drive or viewing.

Valuation
If you would like to apply online for a free valuation of your car you will be required to supply: your vehicle registration number , approximate mileage, postcode, name, mobile number (we need this to send you a validation code to reveal your valuation) and email address. Your details will be used to provide an estimated online valuation which is based on our assumptions and the limited details about your car that you have shared with us. We always carry out a full inspection on-site before we offer to either part exchange a vehicle or to buy it.

If we think that anything in the car’s history or condition will affect its value,
including damage, unusual features or customisation, the price that we offer for it will be different to the valuation we gave you online.

Finance Applications
If you would like to apply for finance online you will be required to complete a finance application on our website and supply your name, email address, telephone number, date of birth, marital status, driving license type, residential status, monthly income, employment type and duration. If you make an application, your details will be held and used in a credit scoring or other automated decision-making process when assessing your application, multiple finance companies on our lending panel may receive this information in order to
consider it.

The contact information will also be used contact you to enable us to inform you
of your status of your finance application. If your finance application is incomplete or incorrect we will contact you to offer assistance. By submitting personal information to us, you are deemed to have agreed to the terms set out
above regarding the use of your personal information.

B. Collected at LJI Investments Ltd (Online Cars Direct)
Website or Showroom; We collect the following information by creating or updating your unique Customer Record Form (“CRF”) : name, telephone number, email, postcode, gender, your thoughts on the vehicles you have viewed, proposed method of funding the vehicle purchase, whether you require finance or part exchange and your driver’s licence details.

Due to our belief that customers should be able to view cars by themselves at their own leisure, customer’s contact details and identifying information are required to establish a record and track the possession of keys, what cars are being viewed and when. In order to facilitate a test drive, your driver’s licence number will also be recorded. If a passport or driver’s licence is scanned to auto-populate the CRF your image will be cropped onto the form. Our system will also automatically flag if your driver’s licence details do not meet our test drive requirements by checking the length the licence has been held by you and also your age.

Information recorded will be primarily used to help support your car buying journey. This includes contacting you following your visit to offer assistance in the event that you have been unsuccessful in finding the right car.

Your CRF will also be relied upon in the event that a Health and Safety or Security matter requires it, where necessary CCTV operated on our premises will be used in conjunction. This may include contacting you or passing on your details in the event of the emergency services requiring access to them. Please note that most service related conversions at our service desks and on the phone are recorded for Training and Compliance purposes and are utilised in the event of addressing a complaint and to providing feedback to staff where applicable.

Vehicle Valuation
Alongside a physical inspection, information about your current vehicle is required in order to provide a valuation of the vehicle. The information we require includes the car registration plate, make, model, vehicle mileage, price required and whether the vehicle has had paint protection applied to it.

Finance Applications
In addition to information collected, in order to complete a finance proposal, the following information is required: date of birth, nationality, residence status, marital status, number of dependent children, ID type available, address, current employment details, proof of employment and previous employment details. Financial details also required include: bank details, income, expenditure, home valuation, assets valuation, whether this is a replacement loan, whether a change in your circumstances is currently expected and also the purpose of the vehicle under consideration for purchase is recorded. In submitting a finance application, your details are held and used in credit scoring or other automated decision-making processes.

Other services
We provide a number of specialised communications at your request to assist in the car buying process such as call backs and test drive bookings. These and any similar processes will be saved on your CRF. We may require further information from you to be able to complete and provide the service requested. Please get in touch with a member of our team for more information.

Post-sale
In addition to the data collected initially via your CRF, your address, the registration number of the vehicle purchased along with any additional products or services required is also collected. Your address is used to verify your identity alongside bills and other methods of identification. Any correspondence received in the course of facilitating an after-sale service will also be recorded.

For marketing communications
We may automatically contact you with regard to our services, for example, with updates to your requests, applications or appointments.

Subject to your consent, we may use your personal information to contact you with information about offers, news and promotions. When you contact us we will not use or pass on your personal information unless you have requested that we do so in order to obtain you funding for your vehicle. We do not use your personal information for marketing or offers unless you have asked us to contact you in the case of a particular vehicle comes available.

Remember that if you say you do not wish to receive any promotional material from us, this will preclude you from receiving any of our offers, news or promotions which may be of interest to you.

6. How do we protect your information?

LJI Investments LTD will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Our team constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction.

Our security measures include:
• Regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
• Daily testing of our security and IT systems;
• Security controls which protect our infrastructure from external attack and unauthorised access; and
• LJI Investments policies outlining our data security approach and training for employees.

All information (except Payment Card information) you provide to us is stored on our servers and or on a leading technology providers. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

7. How may we disclose your data to third parties?

In order to deliver a high standard of support we will provide information about you:
• With your agreement, to additional service providers whose products and services may be of interest to you, such as mechanical breakdown insurance or exterior and interior car protection products; and
• For the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any information that we collect with the police, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation. This may also include public authorities, insurance companies, finance companies, automotive advertising companies and/or other agencies;
• In order to comply with any legal or regulatory requirements;
• To finance companies, if making a finance application through LJI Investments Ltd
• To credit reference agencies, if making a finance application through LJI Investments Ltd
• We will not pass on your personal information to third parties except in accordance with this policy and our Terms and Conditions.

8. What are your rights?

Depending on the legal basis we have relied upon to process your data you have various rights you can choose to exercise. All requests will be considered by the Compliance Department or relevant Department Management and responded to within 28 days of receipt. Requests can be made either in person, by email compliance@onlinecarsdirect.uk) or over the phone 07870222999 during our office opening hours.

Erasure
If you feel that there is no compelling reason for your personal data to continue to be processed you can request erasure. If consent was originally obtained this can simply be withdrawn. In other circumstances the request will be considered by the Compliance Department.

Portability
In event that data has been processed on the basis of consent or for entering into or the performance of a contract you may request to have the data provided to you in a structured, commonly used and machine readable form (usually in CSV format).

Object
If you no longer wish your data processed due to grounds relating to your particular situation, where we are relying upon legitimate interests, you can exercise your right to object. Other rights include the right to be informed about how your personal data is processed, to request rectification if you feel data is inaccurate or incomplete and related to automated decision making including profiling. You also have the right to have processing restricted in the event of contesting the accuracy of your personal data, where you have objected to processing and if you require the data to establish, exercise or defend a legal claim.

Please visit the Information Commissioner’s Office website ico.org.uk if you require more information. If you are unhappy with the response following your request or you would like to make a complaint about how your data has been processed please refer to the Information Commissioner’s Office at https://ico.org.uk/concerns/ who are the supervisory authority in this area.

9. How do we use cookies and how they benefit you?

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. Our cookies help us:
• Make our website work as you would expect;
• Save you having to register every time you visit My Garage;
• Remember your settings during and between visits;
• Improve the speed and security of the website;
• Allow you to share pages with social networks, like Facebook;
• Continuously improve our website for you; and
• Help our marketing be more targeted to your needs.

We do not use cookies to:
• Collect any personally identifiable information (without your express permission);
• Collect any sensitive information (without your express permission);
• Pass personally identifiable data to third parties; or to
• Pay sales commissions.

10. Granting us permission to use cookies

If the settings on your software to view this website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you have accepted the use of our cookies.

Should you wish to remove or not use cookies from our website you can learn how to do this below. However, doing so will likely mean that our site will not work as you would expect. Cookies don’t harm your computer. Like other online companies, we use cookies to provide you with more relevant and useful information. We don’t store personally identifiable information such as credit card details, but we do use information gathered from cookies to help improve your experience of our website.

Anonymous Visitor Statistic & Performance Cookies
We use cookies to compile visitor statistics, such as how many people have visited our website, what type of technology they are using (e.g. Windows, Mac or Android) which helps us to identify when our website isn’t working, how long our customers spend on our website, what page they look at etc and so forth. This helps us to continuously improve our website.

These “analytics” programs also tell us, on an anonymous basis, how people reached our web site (e.g. from a search engine) and whether they have been here before, helping us to develop our services for our customers. All information these cookies collect is aggregated and therefore anonymous. If you do not
allow these cookies on your browser we will not know when our customers visited our site, and will not be able to improve its performance.

Advertising
Cookies are widely used in online advertising. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies. They will be used to build a profile of your interests and show you relevant adverts on other sites. They do not store direct personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

You can learn more about online advertising at http://www.youronlinechoices.com. You can opt-out of almost all advertising cookies at http://www.youronlinechoices.com/uk/your-ad- choices. It is also worth noting that opting out of advertising cookies will not mean you won’t see adverts, just simply that they won’t be tailored to you any longer.

Third Party Cookies
Our website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video or pulling through Feefo Reviews. Disabling these cookies will likely break the functions offered by these third parties.

Site Improvement Cookies
From time to time we test new designs or website features. We do this by showing slightly different versions of our website to different people and anonymously monitoring how our website visitors respond to these different versions. We might also use anonymised heat mapping software to understand popular pages and specific functionality on our website. This helps us to offer you a better user experience.

Remarketing Cookies
You may notice that sometimes after visiting a website you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves, pay for these adverts. The technology to do this is made possible by cookies, and as such, we may place a so called “remarketing cookie” during your visit. We use these adverts to offer targeted Social Website Cookies.

These cookies are set by a range of social media services that we have added to the website to enable you to share our content with your friends and other networks. They are capable of tracking your browser across other websites and building up a profile of your interests. This may therefore impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.

When do our cookies expire?
Except for essential cookies, most of the cookies on our websites expire at the end of your current session on our website. However, some of our cookies have an extended lifespan which ranges from 1 day to 26 years. Some of our cookies are persistent and will never expire. If the cookie used is a flash cookie, please note that flash cookies do not expire.

11. Turning Cookies Off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our’s and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

Amending cookies setting in different types of browser:
Cookie settings in Edge – https://support.microsoft.com/en-us/help/196955

Cookie settings in Firefox – https://support.mozilla.org/en-GB/kb/enable-and-disable-
cookies-website-preferences

Cookie settings in Chrome – https://support.google.com/accounts/answer/61416
Cookie settings in Safari – https://support.apple.com/kb/ph21411

It may be that your concern around cookies relates to so called “spyware”. Rather than switching off cookies in your browser, you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered