PRIVACY POLICY 9DS
1.1
We take the use of your information very seriously, we are committed to…
• Being transparent with you about the information we hold, and how we use it.
• Taking care of your information and keeping it safe.
• Securely removing your information once it is no longer required.
1.2
This Privacy Policy, together with our Terms and Conditions at www.9ds.co.uk (the Website) and any other documents referred to on it, set out the data processing we (9ds Limited) carry out.
1.3
Any updates to this policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back regularly for any updates or changes.
2
who is the data controller?
2.1
For the purpose of the General Data Protection Regulation (the Act), the data controller is 9DS Limited whose registered office is 3, 24A Branksome Wood Road, Bournemouth Dorset BH4 9JX
what types of information are collected?
3.1
When we first create an account for your company, we may need to collect
3.2
If your company goes on to become a full member of 9DS we will need to take payment details.
3.3
We will collect some usage information when you use the Website for example the listings you place, the VRM lookups you perform, the number of times you log-in etc.
4
how is the information collected?
4.1
We collect information in various ways
• When you submit it to us as part of your company’s initial registration on our Website.
• When we follow up with you, to complete your company’s registration, by telephone or by email.
• When we verify the information you have provided to us with regulatory bodies such as Companies House, as part of our due diligence.
• When you contact us to inform us of any subsequent change of personnel or contact details for your company.
• When we periodically update the information we hold for your company, by telephone or by email (if there have been any changes at your end).
• When you use the Website, by posting a listing to other franchise dealers for example.
4.2
We also collect anonymised usage and analytics information for the Website using Google Analytics.
5
on what legal basis is the information used?
5.1
The legal grounds on which we are using your information depends on your relationship with us.
5.2
If you an account holder or have registered with us with a view to becoming an account holder, then the legal basis for our use of your information is our “contractual obligation” to you.
5.3
If you aren’t an account holder or currently in the process of joining us as an account holder, for example if you have left us or we are only occasionally letting you know about our services, then the legal basis for our use of your information is “legitimate interests”.
5.4
Examples of our legitimate interests include
• Helping our account holders to buy and sell and tradeswap vehicles to other members of the franchise network.
• Direct marketing to let you know about our service.
• Ensuring that the information we send is relevant to you and going to the right person.
5.5
When we use your information for “legitimate interests” we will balance our needs against your rights ensuring that…
• The use of your information is likely to be of benefit to you and the account holders of 9DS.
• Any information sent to you, including details of vehicles available to buy, is strictly relevant to the interests of your business.
• The use of your information is minimal and that we couldn’t achieve the same result in a different way.
• We are not ignoring your rights or causing a nuisance.
• That you can easily unsubscribe from any unwanted emails via the unsubscribe link at the bottom of the email.
5.6
In certain circumstances we might also need to use your information to meet our “legal obligations”, for example if we need to assist the police in investigating a suspected crime.
6
how is the information used?
6.1
We use your information to
• Provide, personalise and improve our services (including the Website and its security).
• Respond to any inquiries or requests from you.
• Administer our website (including troubleshooting, data analysis, testing and research).
• Administer orders and accounts relating to our suppliers or customers.
• Maintain information for reference.
• Carry out market research campaigns.
• Provide you with information about our services or to notify you of any changes.
• Suppress any future communications if you ask us to stop contacting you.
6.2
The personal information you provide in relation to any listing on our Website will be processed by us and displayed to other dealers or users of our system to allow them to contact you.
7
how long do we keep your information for?
7.1
We will not keep your information any longer than required. We will securely destroy any information once it is no longer required to
• Fulfil our contractual obligations to you.
• Comply with any legal obligations, for example retaining VAT records.
• Serve the interests of our other dealers or users of our system.
• Respond to requests for information from the police when investigating a suspected crime.
• Suppress any future communications if you ask us to stop contacting you.
8
do we share your information?
8.1
We will never sell or rent your personal data to any other organisation.
8.2
As part of providing our service, selected third parties who are providing services on our behalf, may necessarily have some access to your information. For example
• Our hosting company who develop the Website, make it available online, and keep it secure.
• Our email provider who send the emails from the website to you.
• Our bank account verification provider, where we set up a Direct Debit for you.
8.3
Where such third parties have any access to your personal information we will ensure that a Data Processing Agreement is in place between ourselves and the third party, and that they understand their responsibilities to keep your information safe, and in a way that is consistent with this Privacy Policy.
8.4
We may also need to disclose your information to third parties in order to…
• Comply with any legal obligation.
• Enforce or apply our Website’s terms of use.
• Protect the rights, property or safety of 9DS Limited, or our other users.
9
cookies
9.1
We use cookies to…
• Monitor information entered by you (as you navigate through the Website).
• Distinguish you from other users to allow you to log-in to the Website.
• Deliver content specific to your interests based on information which you have entered and to save your password so you do not have to re-enter it for each page you visit.
9.2
As our security relies on cookies, the Website will not allow you to log in with this facility disabled.
9.3
Cookies are used "per-session" which means that we do not continue to monitor them after you have left our site and you are not obliged to retain them on your computer once you have left our site.
10
other websites
10.1
Any customer or supplier websites which are linked from the Website are outside our control and are not covered by this Privacy Policy.
10.2
If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their own privacy policy, we cannot accept any responsibility or liability for third-party websites or their policies.
11
your rights
11.1
The General Data Protection Regulation, gives you a number of rights. You have the right to
• Transparency over how we use your personal information (your right to be informed).
• Request a copy of the information we hold about you, which will be provided to you within one month (your right of access).
• Update or amend the information we hold about you if it’s wrong (your right of rectification).
• Ask us to stop using your information (your right to restrict processing).
• Ask us to remove your personal information from our records (your right to be 'forgotten').
• Object to the processing of your information for marketing purposes (your right to object).
• Obtain and reuse your personal information for your own purposes (your right to data portability).
• Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
11.2
If you would like to know more about your rights under data protection law see the Information Commissioners Office website.
11.3
Remember, you can change and modify the information you have previously provided to us. This can be done either through the Website, via email to admin@9ds.co.uk
11.4
You have the right to withdraw or withhold your consent to us processing your personal information for marketing purposes. Please click the unsubscribe link in one of our emails or send us an email to admin@9ds.co.uk if you do not wish to receive information about our services.
11.5
You have the right to remove your information from our database, prevent future communications or to no longer receive our services. This can be done either through the Website, via email to admin@9ds.co.uk or by post to 3, 24A Branksome Wood Road, Bournemouth Dorset BH4 9JX You will need to provide us with sufficient details for us to identify your account.
11.6
If you have any questions about this Privacy Policy, the Website, the practices of 9ds.co.uk or your dealings with us, you can contact us at admin@9ds.co.uk. If you are unhappy with our response or believe we are not processing your information in accordance the law you can write to us making a formal complaint or raise the issue with the Information Commissioners Office.