Introduction

When you use our website or take up our Services, we will collect, store and process personal information about you. Motorwise Online Services Ltd trading as MOTORWISE is committed to protecting and respecting your privacy. Our policy extends to our use of any personal information you provide to us by phone, letter, email, SMS, participation with our social media team through an online platform or supplied in person. The purpose of this statement is to set out how we use any personal information that we may obtain from you.

How to contact us

The data controller is Motorwise Online Services Limited, registered company number 08097560. We are registered with the Information Commissioner's Office (ICO) as a data controller of personal information with registration number Z3492050

Any queries relating to our privacy policy should be directed to:

Motorwise Privacy Officer
Trent House
8 St. George's Avenue
Parkstone
Poole
BH12 4ND

Email: privacy@motorwise.com

Data protection principles

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information, including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR). We are responsible as 'controller' of that personal information for the purposes of those laws.

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:

• processed lawfully, fairly and in a transparent manner,
• processed for specified, explicit and legitimate purposes,
• adequate, relevant and limited to what is necessary,
• accurate and kept up to date,
• kept for no longer than is necessary, and
• processed in a manner than ensures appropriate security.

Use and collection of personal information

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect and process personal data which may include:

• Identity Data – this includes your first name, last name, and title
• Contact data – includes your home address, vehicle collection address (if different), email address, contact phone number(s) or any other phone numbers used by you to contact our customer service number, social media profile if you chose to engage with us using this contact platform
• Financial Data – bank account sort code and account number
• Document Data - such as your V5 vehicle registration document, copies of your driving licence, passport, utility bill and other documents that verify your identity
• Technical data – includes the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site
• Usage data – includes information about how you use our site, page response times, download errors length of visits to certain pages, page interaction information

If you do not provide us (or the third-party service provider) with requested personal information required by law or to fulfil the terms of the contract, we may not be able to perform the contract. In this case, we (or the third-party Service provider) may have to cancel the requested service, but we will notify you if this is the case at the time.

Call Recording

Calls to and from our office are recorded for training & monitoring purposes. Recordings are held for a limited period to fulfil this purpose before automatic erasure.

How your personal information is used

We use your information to offer and provide services to you and to communicate with you. We share your data with third parties where there is a legal obligation to do so or where there is a valid lawful basis. We never sell your data to third parties. By using our service, you agree to our third party service providers contacting you to deliver the agreed contract service or to seek feedback on our service. Generally, we do not rely on consent as a legal basis for processing your personal information.

Personal data uses include:

• To provide a quote
• To accept a quote
• To communicate with you via various formats including telephone, email, sms, social media, online chat service
• To invite a review of our service
• We share your data with third parties only where there is a legal obligation for us to do so or where there is a valid lawful basis as set out in the table below.
• We work closely with third party service providers (data processors) to supply and support our services to you.

Motorwise provides quotes on behalf of third-party service providers. The service provided by these third parties relates to the collection, purchase, re-marketing, or recycling of vehicles. Your personal information is required to be obtained and shared with the service providers to facilitate the Service agreement.

Legal Bases for use of your personal information

We have set out below a description of the ways we plan to use your personal information, and of which legal bases we rely on to do so. We may process your personal information for more than one legal basis depending on the specific purpose for which we are using your information.

Purpose / Activity	Type of data	Lawful basis for processing
To register you as a customer	a. Identity b. Contact c. Financial	a. Performance of a contract with you
To provide you a Quote	a. Identity b. Contact c. Transaction d. Profile e. Marketing and Communications	a. Performance of a contract with you b. Necessary for our legitimate interests (or those of the Service Provider)
To carry out the contract agreement between us or between you and the Service Provider	a. Identity b. Contact c. Financial d. Transaction e. Profile f. Marketing and Communications	a. Performance of a contract with you b. Necessary for our legitimate interests (or those of the Service Provider) c. Necessary to comply with a legal obligation
To contact you in connection with the contract delivery and respond to any enquiries in connection with this	a. Identity b. Contact c. Financial d. Transaction e. Profile f. Marketing and Communications	a. Performance of a contract with you b. Necessary for our legitimate interests (or those of the Service Provider) c. Necessary to comply with a legal obligation
To request feedback on your experience	a. Identity b. Contact c. Technical d. Transaction e. Profile f. Marketing and Communications	a. Performance of a contract with you b. Necessary for our legitimate interests (or those of the Service Provider)
To administer our site and for internal operations, including troubleshooting, data analysis, testing, system maintenance, research, statistical, reporting and survey purposes	a. Identity b. Contact c. Technical d. Profile e. Usage	a. Necessary for our legitimate interests (or those of the Service Provider) b. Necessary to comply with a legal obligation

'Legitimate Interest' means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

'Performance of Contract' means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

'Comply with a legal obligation' means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Disclosure Of Your Personal Information

We may share your information with selected third parties including:

• Service Providers, if it is necessary for them to enter into a Service Agreement.
• 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.
• Professional advisers and service providers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• The DVLA, HM Revenue & Customs, regulators and other authorities who may require reporting of processing activities or release of customer personal data in certain circumstances.

We require all third parties to respect the security of your personal information and to comply with applicable personal data processing regulations and requirements. Third party service providers are only permitted to process your personal information for specified purposes related to the services they are providing to us or you in accordance with our instructions.

We may disclose your personal information to third parties where we are under a duty to disclose or share your personal data (including electronic identifiers such as IP addresses) to comply with any legal obligation. This includes exchanging information with the police, fraud prevention agencies and other companies and organisations for the prevention or detection of crime and the purposes of fraud protection and credit risk reduction. Data may also be released to third parties if we are required to do so under the terms of a court order. We will release your personal information when we are required to do so for legal or regulatory purposes or as part of legal proceedings.

How We Store and Protect Your Personal Information

The data that we collect from you will be stored in the cloud, specifically on servers provided by Amazon's AWS service in their Ireland region ('eu-west-1'). Any payment transactions will be encrypted. Phone recordings are encrypted and stored on our secure on-premises server (UK).

Access to your personal information is limited to those employees, Service Providers, contractors and other third parties who have a business need to know. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will not however be responsible for any breach of security unless this is due to our negligence or wilful default.

How long we will store your personal information

The length of time that we will store your data will depend on the 'legal basis' for why we are using that data. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of complying with any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

• Your right to be informed of how we intend to use your information is detailed in this policy
• You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
• You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
• You have the right to ask us to erase the information we hold about you (the 'right to be forgotten'). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
• You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
• You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly used, and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
• Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
• Where we use/store your data because you have given us your specific, informed, and unambiguous consent, you have the right to withdraw your consent at any time.
• You have the right to object to us using/storing your information for the purpose of contacting you regarding your valuation.

If you believe we are not complying with the laws and regulations relating to the use/storage of your personal data, we would appreciate it if you would contact us in the first instance. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. If it becomes evident that we may need longer than a month, we will notify you and keep you updated.

You have the right at any time to lodge a complaint about the way your personal data is handled by us to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you wish to exercise any of your legal rights, please contact our Data Manager by writing to the address at the top of this policy, or by emailing us at privacy@motorwise.com.

Cookies

Our website uses cookies which help us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Cookies do not contain confidential information such as your home address, telephone number or credit card details. We do not exchange cookies with any third party websites or external data suppliers. We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Except for essential cookies, all cookies will expire after two weeks.