Who are we?
Our services are not intended for children and we do not knowingly collect data relating to children.
What do we do with the information we collect?
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 may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you don’t provide false, inaccurate information or impersonate another individual.
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender. It also includes images of your face and appearance when appearing on video footage or photographs when you attend any of our events.
Contact Data includes billing address, delivery address, email address, and telephone numbers.
Financial Data includes bank account and payment card details
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting, and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, unique account reference number, bids, offers, and purchases made by you on the platform, your search preferences, feedback, survey responses, and other correspondence.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes correspondence with us and your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How do we collect your personal information?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms, providing documentation, or corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
(a) apply for our services;
(b) purchase or use of our platform and services;
(c) create an account on our website, or otherwise;
(d) subscribe to our services or publications;
(e) request marketing to be sent to you;
(f) contact us to report a problem with the website or services, or for other purposes;
(g) enter a competition, promotion, or survey;
(h) upload an advert or create a listing on our website; or
(i) Give us feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(a) Technical Data from the following parties: analytics providers based outside the EU, such as Google Analytics;
(b) Identity and Contact Data from Know Your Customer Services.
What do we do with your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email, or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing|
|To register you as a new customer or user||(a) Identity(b) Contact(c) Profile||Performance of a contract with you|
|To provide the services to you including (a) Managing payments, fees, and charges(b) Collect and recovering money owed to us||(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)(c) Necessary for the legitimate interests of others (preventing fraud)|
|To manage our relationship with you which will include:(a) Notifying you about changes to our terms and conditions or services (b) Asking you to leave a review or take a survey||(a) Identity(b) Contact(c) Profile(d) Marketing and Communications||(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business, and to inform our marketing strategy)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)|
|(a) Performance of a contract with our customers(b) Necessary for our legitimate interest (to support our business model)||(a) Technical(b) Usage||To use data analytics to improve our website, services, marketing, customer relationships, and experiences|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications||Necessary for our legitimate interests (to develop our services and grow our business)|
|To enable you to search for and purchase vehicles on our marketplace||(a) Identity(b) Contact(c) Profile||(a) Performance of a contract with our customers(b) Necessary for our legitimate interest (to support out business model)|
Promotional offers from us. We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which services, updates, news, and offers may be relevant for you in our marketing activities.
You may receive marketing messages from us if you have requested information from us or used or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion, in each case, you have opted to receive that marketing.
Third-party marketing. We will get your express opt-in consent before we share your personal data with any company outside Just Land Rovers for marketing purposes.
Opting out. You can ask us or third parties to stop sending you marketing messages at any time by contacting us or unsubscribing to the third party’s marketing list.
Where you opt out of receiving these marketing messages, we will cease processing your personal data for this purpose. It will not apply to personal data provided to us as a result of your position as a customer or user of our website, or other services, or in relation to a transaction, as we may still need to communicate with you about these services.
Change of purpose. We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How do we protect your personal information?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting 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 with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are provided in all the privacy notices displayed whenever you provide us with your personal data and will vary according to the purpose for which they are collected.
We keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: See below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How can you access, amend, or delete the information we have on you?
Your Legal Rights. You have the right to:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.c
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
i. If you want us to establish the data’s accuracy.
ii. where our use of the data is unlawful but you do not want us to erase it.
iii. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(g) Request the transfer of your personal data to you or to a third party.
(h) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How do you contact us?
(a) Full name of legal entity: GRAMART Limited
(b) Email address: Please use the contact form.
(c) Postal address: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ
11.2 Information Commissioner’s Office: You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.