Smooglei limited t/a PriceMyCar (“Price My Car”), a company incorporated under the laws of Ireland and the United Kingdom (“we“), are committed to protecting and respecting your privacy.
our website https://pricemycar.net (“our site” or “the site”) and the PriceMyCar™ application ( “our app” or “the app”) are both operated by appraisee.
Our app and site are used by our clients to allow our clients to carry out appraisals of vehicles on the go electronically. The appraisals are then processed and stored by us. As part of this process, we collect personal data in relation to the following:
“appraisers”: the employees of our clients who are using the app to carry out appraisals; and
“customers”: the owners of the cars being appraised.
On our site or app, personal data in relation to appraisers and customers will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site:
- information provided at the time of registering to use our site, such as name and login information and password;
- information posted by you on our site or app;
- payment details to purchase services on our site;
- Statistical information about browsing actions including, but not limited to:
- traffic data;
- location data: we gather location data to track location specific appraisals carried out by appraisers; and
- weblogs and other communication data.
- Details of transactions you carry out through our site and of the fulfilment of your orders.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes and if you choose to complete the survey we hold this information for research purposes.
PURPOSE OF PROCESSING
The purpose of the processing of your personal data is to fulfil our contractual obligations with our clients.
The specific purposes are set out below:
- Customers’ personal data: We process personal data of customers in order to provide the appraisal service offered by our clients and in order to provide customers with copies of the appraisal reports when requested by customers. The lawful basis for the processing is the provision of the appraisal services by our clients to their customers and the contract in place with our customers.
- Appraisers’ personal data: We process personal data of appraisers in order to set up their profiles and allow them to manage the appraisal process through the app and site and in order to track their activity and productivity as required by the client. The lawful basis for processing this personal data is the provision of the services offered by the app and site to our clients and the contract in place between our clients and us.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes (more detail is provided below in relation to direct marketing).
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
LEGAL BASIS FOR PROCESSING YOUR DATA
Under GDPR the main basis that we rely upon to process personal information about users on our site is as follows:
(a) performance of a contract – in order to perform obligations that we undertake in providing a service to you or through our clients, or in order to take action at your request to enter into a contract with us, it may be necessary for us to process your personal data;
(b) legitimate interests – either we, or a third party, may be required to process your personal data for the purposes of our (or a third party’s) legitimate interests. If we do so we must establish that such interests are not conflicted with your rights including the protection of your personal data. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our site and customer experience, informing you about our products and services, and ensuring that our operations are conducted in an appropriate and efficient manner.
(c) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
RETENTION OF YOUR DATA
We shall retain personal data for strictly no longer than is necessary for:
- the purposes for which it was collected;
- for as long you maintain an active profile on the site or app; and
- for 2 years following expiration of the contract with our client; and
- (b) as required to fulfil our obligations in law.
- the purposes for which it was collected;
STORAGE AND SHARING OF YOUR PERSONAL DATA
All transfers of data outside of the European Economic Area (the “EEA”) are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”) and are based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot absolutely guarantee the security of your data transmitted to our site; 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.
SECURITY OF YOUR DATA
In order to ensure the security of your personal data, appraisee shall ensure the security of the information that we collect and shall store it in a safe manner. We have the following measures in place (although we cannot always guarantee the security of data that is collected and stored by us):
- where our employees or contractors process personal data, we will ensure that they are trained in the handling and care of personal data and that such employees or contractors are only permitted access to personal data on a “need to know” basis;
- we will ensure that all inquiries from data subjects relating to the processing of their personal data by appraisee are dealt with promptly and properly;
- we maintain appropriate technical, security and organisational security measures against any unauthorised access to or alteration, disclosure, destruction, or accidental loss or destruction of or damage to personal data. We will carry out regular testing of the effectiveness of our security measures to minimise risk;
We will maintain a list of any sub-processors available upon request.
DATA PROTECTION INCIDENT
Upon becoming aware of a breach of personal data we will notify affected data subjects within 72 hours in writing, detailing the circumstances and particulars thereof; report the breach to the Data Protection Commissioner of Ireland & the United Kingdom (the “Supervisory Authority”); and take such reasonable corrective and mitigating measures as required under Data Protection Law and that are customary under the circumstances.
IP ADDRESSES, COOKIES AND GOOGLE ANALYTICS
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. Aggregate information is statistical data about your browsing activities and patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and to allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
We also use Google Analytics on our site. Google Analytics transmits website traffic data to Google servers in the United States, but it does not identify individual users or associated IP addresses with any data held by Google. We use reports provided by Google Analytics to better understand traffic and usage of our site.
Your rights relating to personal data:
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
- right to access your personal data: you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data;
- right to rectification: you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete;
- right to erasure: you have the right to request that we delete personal data that we hold about you;
- right to restriction of processing or to object to processing: you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes;
- right to data portability: you have the right to request that we provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format;
- Consent – to the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.
To exercise these rights please email firstname.lastname@example.org
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Companies Act 2014.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If appraisee or its business assets (or substantially all) are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.