ADESA Remarketing Privacy Notice
Date last revised: May 25, 2018
ADESA Remarketing Limited (“ADESA” or “we”) has developed a comprehensive privacy program designed to respect and protect your data privacy rights. This Privacy Notice explains what information, including any personal information, we collect through our Internet websites located at https://adesa.co.uk and all subdomains thereof (the “Sites”) and any services, content or functionality available through or on the Sites and any mobile applications (collectively, together with the Sites, the “Service”), and how we use that information.
For the purposes of applicable data protection law, the data controller is ADESA Remarketing Limited of Deva House, Sandpiper Court, Chester Business Park, Chester CH4 9QZ.
Information We Collect
In general, you can visit our Sites without telling us who you are or revealing any personal information about yourself. In fact, we encourage anonymous surfing so that you can research remarketing solutions, help streamline business communications and other processes. You can also log in to research vehicles. During this process, there are times when we may need and request information from you so that we can better serve you. We may also receive information from other sources.
Information we collect may include the following:
- Name and job title
- Contact information including email address and telephone
- Demographic information such as postcode, preferences and interests
- Information relevant to customer surveys and/or offers
- Information provided to us through forms and other inputs on the Sites
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, mobile location information
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site including date and time, vehicles you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number
Mobile applications may also disclose certain permissions for certain device settings such as CAMERA, RECORD_AUDIO, READ_PHONE_STATE, GET_ACCOUNTS and READ_CONTACTS.
How We Use Your Information
We may use this information to provide you with products and services as well as for the following purposes:
- Internal record keeping
- Improvement of our products and services
- Customisation of the Sites per your interests
- Periodic promotional emails about new products, special offers or other information
- To contact you via the contact methods you provide for market research purposes or in relation to your account.
Basis for Processing
We rely on the following legal basis for processing your personal information:
(i) legitimate interests to market to customers and conduct analytics; and necessary for the performance of a contract, with some processing based on (ii) consent, such as electronic direct marketing.
Disclosure of Information to Third Parties
In connection with the purposes set out above, we may share your information with:
- Any member or affiliate of our group
- Selected third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- parties based outside of the European Economic Area (for example, our parent company in the United States) under a transfer mechanism(s) used to legitimate such transfers (e.g. model contractual clauses).
We may also disclose your information to third parties:
- To provide needed information to our agents, partners and contractors who may provide products and/or services to you
- As necessary to support transactions
- In the event that we sell or buy any business or assets, in which case we will disclose your information to the prospective seller or buyer of such business or assets
- If 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 or apply any of our terms and conditions and other agreements
- To protect our company’s (including its affiliates and their respective employees, sub-contractors, agents, and customers) rights, property or safety including, but not limited to, exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Protecting Your Information
We are committed to protecting the information entrusted to us. We have implemented reasonable and appropriate physical, electronic and administrative procedures to safeguard this information from loss, misuse, unauthorized access or disclosure, alteration and destruction.
Storing Your Information
The information that we collect from you is stored on our secure servers. It shall be stored for as long is as reasonable necessary for the purposes for which it was collected.
We may, from time to time, and subject to our Privacy Notice, use technologies similar to cookies, including web beacons, pixel tags, flash objects, location tracking and/or third party widgets for purposes of enhancing your web or mobile experience and/or for purposes of allowing you to share information on another platform, such as a social media platform.
For more information on the types of cookies we collect, to control cookie settings and/or to disallow, delete and otherwise manage the cookies, please visit our “Privacy Preference Centre” with additional information about the different types of cookies used (e.g., strictly necessary, performance, functional, targeting) and your options for settings controls. You may also send an email to Privacy@adesa.co.uk.
Please note that e-privacy rules require us to obtain your prior consent before sending any electronic direct marketing by email, SMS or text messaging. In addition, you have the right to withdraw your consent to direct marketing and/or object to it.
Third Party Links
We may provide links to third party Internet sites strictly as a service to you. We are not responsible for the privacy practices of third party Internet sites. If you leave the Sites, you should be sure to read the privacy notice of each Internet site that you visit.
Transfer of Personal Information from EEA and Switzerland
We will store your personal information within the European Economic Area.
On occasion, we may send data to Canada for technical support purposes. Canada has data privacy protections that are currently deemed adequate by the European Commission. If we have to share your personal information outside of the European Economic Area to a country with data privacy protections that are deemed inadequate by the European Commission (for example, with our parent company in the United States) we plan to do so under a transfer mechanism(s) used to legitimate such transfers (e.g. model contractual clauses).
Changes to this Privacy Notice
It is our policy to post any changes we make to our Privacy Notice on the Sites. If we make material changes to how we treat the personal information that falls within the scope of this Privacy Notice, we will notify you by email to the email address specified in your account or through a notice on the Site. The date that this Privacy Notice was last revised is identified at the top of the page. Please periodically visit the Site and this Privacy Notice to check for any changes.
Your Rights in Relation to Your Personal Information
You have various rights under data protection law regarding the processing of your personal information, including rights to the following:
- request access to personal information we hold about you and details of our processing of your personal information;
- request us to correct inaccurate personal information;
- request us to delete personal information in certain circumstances;
- receive your personal information in a format suitable for transmission to a third party;
- object to and/or restrict the processing of your personal information (including profiling) on certain grounds;
- object to the processing of your personal information for direct marketing;
- object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
- lodge a complaint with the UK Information Commissioner’s Office.
Subject Access Requests
You can make a request to us in relation to these rights at any time by writing to us at the following local address: Data Privacy Manager, ADESA Remarketing, Deva House
Chester Business Park, Cheshire CH4 9QZ. You may also send an email to Privacy@adesa.co.uk or submit a Subject Access Request. Any information to which you are entitled will be provided within a reasonable timeframe, subject to the exemptions stipulated in applicable data protection laws.
If you believe that any information we are holding about you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.