carwow.co.uk, carwow.es, and carwow.de provide an online service owned and operated by carwow Ltd or its subsidiary companies (“carwow”, “we” or “us”). Please take the time to review this privacy statement which explains the information that carwow collects about you, how we use it, and your rights in relation to that information.
carwow Ltd of 2nd Floor, 10 Bressenden Place, London, SW1E 5DH, United Kingdom is the data controller of the personal information collected via or in connection with our websites (carwow.co.uk, carwow.es, and carwow.de) and our app (the “sites”).
What personal information do we collect about you?
We collect personal information from you when you provide it to us directly and through your use of the sites. This information may include:
- Information you provide to us when you create an account with us, which will include your name, email address, postcode and password;
- Information you provide when using the sites, for example your telephone number, searches, reviews and comments;
- Any correspondence you have with dealers via our sites;
- Records of your interactions with carwow (e.g. if you contact our support team). We maintain a record of and recordings of telephone calls to and from dealers made in connection with the carwow service for quality control and training purposes;
- Information you provide to us when you enter a competition or participate in a survey; and
- Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our sites, your IP address and your browser or operating system type and version.
We may also receive confirmation from one of our dealers if you buy a car from them, for our accounting purposes and to manage the dealer’s account with us.
Car Dealerships and Job Applicants
This privacy statement is primarily aimed at users of our sites. However, if you work for a car dealership with whom we partner or are applying for a job with carwow, please read the below.
If you work for a car dealership with whom we partner, we will collect your business contact details as well as other information relevant to our professional relationship with you, including a photo to display on the sites. We will also maintain a record of your communications with us and with users via our sites.
We may collect information about you from you directly, from your employer, from a user of our sites, or from publicly available sources (e.g. your dealership websites).
We will use this information for the purposes of developing and maintaining our partnership with you. If you would like to update or delete your dealer profile on our sites, please contact us.
If you apply for a job with carwow, we will collect and use the information you provide to us in the course of your application to assess your suitability for the position you have applied for and for other roles in the future, and to monitor diversity and equal opportunities within our recruitment process. Please note that as part of the application process, we may also collect information about you from third parties, for example recruiters, referees, or from publicly available sources (e.g. LinkedIn). Please visit our sites for more information about careers at carwow, or contact us using the details below.
What do we use this personal information for?
Depending on how you use our Sites, your interactions with us, and the permissions you give us, the purposes for which we use your personal information include:
- To fulfil requests submitted via the sites and maintain your online account;
- To contact you about your use of the sites and send you car offers;
- Where you contact a dealer via our sites, carwow (or its service provider) may telephone you to confirm whether you bought a car from that dealer. This telephone call may be recorded for training and quality control purposes;
- To manage and respond to any queries or complaints to our customer service team;
- To personalise the sites to you and show you content we think you will be most interested in, based on your account information and your history on the sites;
- To fulfil our obligations to the dealerships we work with;
- To improve and maintain the sites, and monitor its usage;
- For market research, e.g. we may contact you for feedback about your experience on our sites;
- To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so;
- For security purposes, to investigate fraud and where necessary to protect ourselves and third parties; and
- To comply with our legal and regulatory obligations.
Our basis for processing under UK data protection law
Generally, we rely on your consent to process the personal information collected via our sites, so that we can provide you with the services we offer; for example, when you create an account with us, browse for cars or correspond with dealers via our sites, and you ask us to send you offers about particular cars. You can withdraw your consent at any time (see ‘Storage and Deletion’ below), but if you do so we will need to delete your account and you will no longer be able to conduct any transactions via our sites.
We may also process your personal information where it is in our legitimate interests to do so, in order to maintain our sites and conduct our business. For example:
- We conduct an analysis on our user base and the searches made via our sites;
- We (or our service provider) may contact you after you have used our sites to ask if you have bought a car (so that we can collect commission from the relevant dealer, and for our own internal research purposes); and
- Where you or a dealer confirm that you have found a vehicle via the sites, we will process your personal information in order to fulfil our obligations to the dealers we work with and collect any commission due.
Marketing & Advertising
We love to communicate with our users and so, depending on your marketing preferences, we may use your personal information to send you marketing, including by email, SMS or post. Some of these messages may be tailored to you, based on your previous use of our sites.
If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting firstname.lastname@example.org, email@example.com or firstname.lastname@example.org, clicking on the ‘unsubscribe’ link in any email, or visiting ‘Settings’ in your account.
If you unsubscribe from marketing, please note we will still contact you with service messages from time to time, including to send you offers from dealers in response to a request you make on the sites.
Who do we share this personal information with?
We share users’ personal information with third parties in the following circumstances:
With car dealers, to pass on your interest or specific query. Please note, however, that carwow does not share your full contact details with dealers for contact purposes. The only information which they receive from us is your name and postcode, as well as any information you choose to share via our messaging tool. On occasion we may share your email address with dealers for the purpose of confirming that a particular sale was made through the site;
With our suppliers and service providers, for example we use a service provider to contact you via telephone you to confirm whether you bought a car via our sites;
With third parties for targeted advertising purposes (see Marketing & Advertising above);
With our professional and legal advisors;
With third parties engaged in fraud prevention and detection;
With law enforcement or other governmental authorities, in response to a lawful request or court order;
We also disclose aggregate data, which does not identify any user personally, including to third parties working in media, consumer research and the car industry (for example, as analysis of popular cars in a given year); and
Otherwise where we have your consent or are otherwise legally permitted to do so.
Storage and Deletion
Our sites are hosted by Amazon Web Services which has servers based around the world, and we may use other international service providers. Consequently, your personal information will be processed in countries outside of Europe, including in countries where you have fewer legal rights in respect of your data than you do under local law. Where we transfer personal information outside the European Economic Area we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate safeguards, including by using the EU Standard Contractual Clauses and the EU-US Privacy Shield. Please contact us if you would like more information about these safeguards.
If you would like to delete your account with carwow, please contact us using the details below. Please note, however, that if you delete your account we may retain some of your details (for example if you have made a complaint about our sites), for as long as is necessary to protect us from a legal claim. If you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
Users under 18
Our sites is not intended for, and should not be used by, anyone under the age of 18. We do not knowingly collect personal information from individuals under 18.
You have certain rights in respect of your personal information, including the right to access, correct, and request the erasure of your personal information.
You also have the right to object to your personal information being used for certain purposes, including to send you marketing. See ‘Marketing’ above, for more details of how to opt-out of marketing.
We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, please contact us using the details below. You are also entitled to contact the UK’s supervisory authority for data protection, the Information Commissioner’s Office, or your local supervisory authority.
10 Bressenden Place
Last updated 10th Mar 2020