- Who we are
CarsIOM.im is a web based marketplace that offers a vehicle buying and selling process. To enable you to experience our products and services, we need to collect and process information about you.
- the CarsIOM website at www.CarsIOM.im (the “Website”)
- social media or official CarsIOM content on other websites;
- our mobile devices and Applications (“Apps”)
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.
For the purposes of this Policy, the data controller is SRLTrading.im, 23 Slieau Curn Park, Kirk Michael, Isle of Man, IM6 1EP.
Our Privacy Promise
CarsIOM (“CarsIOM”, “we”, “us”, “our”) are committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it.
It’s important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.
- What information CarsIOM collects about you;
- How CarsIOM collects and uses information about you;
- Whether CarsIOM discloses your details to anyone else;
- The choices available to you regarding the personal information you provide to us;
- When and how your data may be shared with third parties.
Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.
We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and 2011 and the General Data Protection Regulations (GDPR), and including any amendments or updates to these and any equivalent or successor applicable laws and regulations.
- Information collected and how we use it
CarsIOM collects the following information:
Information you provide when you place an advertisement on the Website
As part of the advert placement process on the Website, we collect your name, telephone number, email address and postcode, as well as details of the vehicle you wish to sell.
- We use your name and email address to register your account and place your advert. You can access your account at any time to update your details. We will only use your information for marketing purposes where you have given us specific consent.
- Vehicle Registration Numbers are not required to place an advert on the Website. However, if the Vehicle Registration Number is displayed in photographs within your advert then these details may be visible to Website visitors who may use them without your authorisation.
- When your advert expires you have the option to relist your advert via your account login.
- We may also use the information you provide for internal business records and purposes, including to develop our products and services and the Website.
We reserve the right to monitor and retain all communications via the email service for security monitoring purposes.
If you decide to use our promotional packages to boost your advert or if you are a Trade customer who is paying for account access 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:
Information you provide when you browse or use services on the Website
How we use the information we collect
We use the information we collect to:
- provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services.
- identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits.
Lawful basis we use to process your information
We process your data based on the lawful basis set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:
- Contract: To enter into a contract with you and fulfill our contractual obligations to you (e.g. to publish your advert). This processing is necessary for us to provide the service you have requested including registering and managing your account and providing service updates and our support services.
- Consent: To provide information and take actions in relation to services which you have opted-in to receive. This includes where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers).
- Legal Obligation: Where processing is necessary to comply with legal or statutory requirements on us. This may include cooperating with police in relation to their investigations.
- Legitimate interest: To improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, undertake market research and inform our general marketing, to run our business and maintain the security or our Website and services for you, us and other Website visitors and customers.
Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by dealers.
Where you have given consent for CarsIOM to process your personal data you may withdraw consent at any time by emailing firstname.lastname@example.org. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.
If you have given consent for your details to be passed to a dealer or other third party your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.
- Disclosure of your information
CarsIOM will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:
- We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third party platforms (such as the ‘Facebook Recommend’ or Facebook Gestures’ function). Information about your visit to the Website may be collected by these third party providers on these pages. If you browse these pages whilst still also logged in to your account on the third party platform, information collected by the third party may be connected to your account on the third party platform. 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.
- Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our terms and conditions and any other agreements.
- If we or substantially all of our assets are acquired by a third party, personal data held by us about our customers may be disclosed to the prospective buyer.
- We may share your personal information with our group companies.
- We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies, automotive advertising companies and/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders. .
We are not responsible for any use of your personal data by these parties except where they act as our processor.
- Where we store your personal data
Where we transfer your data outside of the EEA, we will ensure that safeguards are in place to provide a similar degree of protection to protect it. This may include contractual protections in place with our service providers or transferring your data to countries or parties which are recognised as providing suitable protection by the European Commission.
Certain parties to whom we disclose your personal data may transfer your data outside of the EEA 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 data 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, please read their privacy policies or contact them.
CarsIOM uses strict procedures and security features designed to prevent any unauthorised access to your data that we hold.
- Retention period
CarsIOM will process personal data for as long as necessary to fulfill the purpose we collected it for, including the purpose of legal, accounting and reporting requirements, and for as long as necessary for the prevention and detection of criminal activity. The period for which we process and store the personal data for varies depending on the use you make of the Website and the products and/or services we offer. Where you register an account or place an advert we will retain your data for as long as your account and/or advert is live and a period after your account is closed or advert ends to enable us to satisfy our legal, accounting and reporting requirements.
In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.
In some circumstances we may anonymise your personal data (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.
- Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. In the event that CarsIOM refuses your request under rights of access, we will provide you with a reason as to why
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organisation.
- 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 in paragraph 8 below.
- Complaints and Contact
If you wish to make a complaint about how your personal data is being processed by CarsIOM (or third parties as described above), or how your complaint has been handled, in the first instance please email your concerns email@example.com You also have the right to lodge a complaint directly with the Isle of Man Information Commissioner Head Office, PO Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260
If you have any questions regarding the use of your personal data please contact us at: firstname.lastname@example.org
or SRLTrading.im, 23 Slieau Curn Park, Kirk Michael, Isle of Man, IM6 1EP