1 Your privacy
We are committed to protecting your personal information and being transparent about what information we hold and how we use it.
Should you have any queries about this policy please contact the Data Protection Officer directly at email@example.com
2 Relevant legislation
We ensure we collect and process your information in accordance with all applicable privacy laws, the following are applicable:
UK Data Protection Act 1988 (DPA)
EU Data Protection Directive 1995 (DPD)
EU General Data Protection Regulation 2018 (GDPR)
3 What information do we collect and how do we process it?
3.1 What is personal information? Personal information is any information that allows someone to identify you, including, for example, your name, address, telephone and mobile numbers, email address, as well as any information about you that is associated with or linked to, or could be linked to, any of the foregoing data.
3.2 So that we can improve the performance of this website and respond to your enquiries this website collects and processes personal information for the following reasons:
3.2.1 Site visitor tracking
This website uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find our site and how they move through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 10 below).
Our lawful basis for collecting and processing this information is it is necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
3.2.2 Enquiry forms
If you submit any of the enquiry forms on this website your data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Your data is not stored on this website.
The information you supply via the website form is used solely for the purpose of responding to your enquiry.
Our lawful basis for collecting and processing this information is your consent to process your information in order to respond to your enquiry.
4 How do we store your personal information?
4.1 Your personal information will only be stored and processed within the European Union.
4.2 This website is hosted on a Microsoft Azure server within the European Union.
5 How do we keep your personal information secure?
5.1 The website and server have appropriate technical and organisational measures in place to protect against unauthorised or unlawful use of your personal information as well as the accidental loss, destruction or damage of your personal information whilst under our control.
6 Do we share your personal information with anyone else?
6.1. We may disclose your personal information to third parties:
If all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
6.2. Under certain circumstances we may occasionally be required by law, court order or governmental authority to disclose certain types of personal information and we reserve the right to comply with any such legally binding request. Examples of the type of situation where this would occur would be:
- in the administration of justice;
- where we have to defend ourselves legally;
- in complying with the mandatory requirements of a government department collecting information; and
- to protect or defend our rights or property or users of our services.
6.3. Other than this, we will not disclose any of your personal information to any other third parties without your explicit consent.
7. How long will we keep your personal information?
7.1 We retain your personal data only for the period necessary for the purposes set out in this policy and that we believe customers would consider reasonable, or in accordance with the provisions of applicable law.
7.2 Further information on how long we retain your personal information can be found in section 3.2 above.
8. Automated decision making
8.1 We do not use your personal data with any automated decision making processes.
9.1. “Cookies” are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are common and won’t do anything to harm your system – they simply store or gather information. They help you to get the most out of your visit to our website. Further information on cookies can be found here https://ico.org.uk/for-the-public/online/cookies/
9.2 How to control and delete cookies
Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
Please be aware that restricting all cookies may impact on the functionality of our website.
9.3 The cookies that we use:
9.3.1 Site function
Name: ivsp, nvid, pnctest
Description: Cookies used by the iVendi finance calculator included on select car listing pages. The cookies are used for analytics purposes and to deliver the finance calculator functionality.
Duration: ivsp = 1 year, nvid = 1 year, pnctest = 12 years, 3 months. Find out more.
9.3.2 Web analytics
Name: _ga, _gat, _gid
Description: These are used by Google Analytics as described here
Duration: Find out more
9.3.3 Embedded content
We sometimes embed photos and video content from websites such as YouTube and Flickr. As a result, when you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. We do not control the dissemination of these cookies. You should check the relevant third party website for more information about these.
10 Our third party data processors
10.1 We use third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2. The third party listed below is based in the USA and are EU-U.S Privacy Shield compliant.
11 Data breaches
11.1 We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach being identified if it is apparent that personal data stored in an identifiable manner has been stolen.
12 Your rights
12.1 Subject access rights
The GDPR grants you (hereinafter referred to as the “data subject”) the right to access particular personal data that we hold about you. This is referred to as a subject access request. We shall respond within a reasonable period from the time of receiving the request and all necessary information from you. Our formal response will include details of the personal data we hold about you, including the following:
sources from which we acquired the information;
the purposes for processing the information;
persons or entities with whom we are sharing the information.
12.2 Right to rectification
You, the data subject, have the right to obtain from us, without undue delay, the rectification of inaccurate personal data we hold concerning you. Taking into account the purposes of the processing, you, the data subject, have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
12.3 Right to erasure
You, the data subject, have the right to obtain from us the erasure of personal data concerning you without undue delay.
12.4 Right to restriction of processing
Subject to exemptions, you, the data subject, have the right to obtain from us restriction of processing where one of the following applies:
the accuracy of the personal data is contested by you, the data subject, and is restricted until the accuracy of the data has been verified;
the processing is unlawful and you, the data subject, oppose the erasure of the personal data and instead request the restriction in its use;
we no longer need the personal data for the purposes of processing, but it is required by you, the data subject, for the establishment, exercise or defence of legal claims;
you, the data subject, have objected to processing of your personal data pending the verification of whether there are legitimate grounds for us to override these objections.
12.5 Notification obligation regarding rectification or erasure of personal data or restriction of processing
We shall communicate any rectification or erasure of personal data or restriction of processing as described above to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. We shall provide you, the data subject, with information about those recipients if you request it.
12.6 Right to data portability
You, the data subject, shall have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller, without hindrance from us.
12.7 Right to object
You, the data subject, shall have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, including any personal profiling; unless this relates to processing that is necessary for the performance of a task carried out in the public interest or an exercise of official authority vested in us. We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of you, the data subject, or for the establishment, exercise or defence of legal claims.
12.8 Right to not be subject to decisions based solely on automated processing
We do not carry out any automated processing which may lead to an automated decision based on your personal data.
12.9 Invoking your rights
If you would like to invoke any of the above data subject rights with us, please contact the Data Protection Officer named in section 12 below. We will respond to you in a timely manner. In order to action your request we may require you to verify your identity, this is in the interest of protecting the personal information we hold.
12.10 Accuracy of information
In order to provide the service to our members, we need to keep accurate personal data about you. We take reasonable steps to ensure the accuracy of any personal data or sensitive information we obtain. We ensure that the source of any personal data or sensitive information is clear and we carefully consider any challenges to the accuracy of the information. We also consider when it is necessary to update the information, such as name or address changes and you must help us by informing us of these changes when they occur.
13 How to contact us
13.1 The Data Controller of this website is: Cotswold Car Broker.
13.2 The Data Controller’s registered and operating office is:
The Coach House, Church Walk, Ashton Keynes, Swindon, England, SN6 6PB
13.3 The Data Protection Officer is:
Mr. Ian Francomb
15 If you have a complaint
If you have a complaint regarding the use of your personal data or sensitive information then please contact the Data Protection Officer and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 123 1113. You also have the right to judicial remedy against a legally binding decision of the ICO where you consider that your rights under this regulation have been infringed as a result of the processing of your personal data. You have the right to appoint a third party to lodge the complaint on your behalf and exercise your right to seek compensation.