About this Policy
This Policy sets out the essential details relating to your Personal Data relationship with Nought-Sixty Limited. The Policy applies to all Services and any associated Services that Nought-Sixty Limited provides. From time to time, we may develop new or offer additional Services. If the introduction of these new or additional Services results in any change to the way we collect or process your Personal Data we will provide you with more information and additional terms or Policies. Unless stated otherwise when we introduce these new or additional Services, they will be subject to this Policy.
Use of our Website
GDPR – your rights and your preferences – giving you choice and control.
You may be aware that the General Data Protection Regulation or ‘GDPR’ gives certain rights to individuals in relation to their Personal Data. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access – the right to be informed of and request access to the Personal Data we process about you;
- Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
- Right to Erasure – the right to request that we delete your Personal Data;
- Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object:
- the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation;
- the right to object to your Personal Data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service; and
- Right Not to be Subject to Automated Decision-Making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how Nought-Sixty Limited uses your Personal data, you can contact us at firstname.lastname@example.org
If you are receiving communications and / or notifications from us via email or via your web browser or any other digital process, then you can easily manage your access to this information by using the respective unsubscribe mechanism that is readily available with each communication.
General Use of Personal Information
We use information submitted to provide you with further information about the products / Services we offer or to assist you in answering any questions or queries you may have submitted. This includes using your Personal Data to subscribe you to our weekly email, but only if this was made clear to you and your express permission was granted when submitting any form to email process.
How do we collect your Personal Data?
We use different methods to collect data from and about you, and these have been detailed below.
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, or by corresponding with us by phone, in person, email or through Live Chat or any Social Media or digital channel.
This includes Personal Data you provide when you:
- Sign up to receive our weekly emails;
- Make Valuation enquiries or request for a car to be submitted for Auction;
- Create an Account on our Website;
- Bid on a Vehicle for sale on our Website;
- Ask for marketing to be sent to you;
- Engage with us on Social Media;
- Enter a competition, promotion or survey;
- Contact customer services; or
- Leave comments on the Vehicles listed on our Website;
As you interact with us via the Nought-Sixty Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our Website, or when you click on one of our adverts (including those shown on third party websites).
We may receive Personal Data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
- Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
- Identity Data and Contact Data from data partners; and
- Data from any third parties who are permitted by law or have your permission to share your Personal Data with us, such as via Social Media or review sites. We will only use your personal data when the law allows us to.
What Personal Data do we collect from you?
- 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).
- Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through Social Media, this may include your Social Media user name.
- Contact Data includes addresses, email addresses and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and Services you have Purchased from us.
- Profile Data includes your username and password, Purchases made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
- 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 our Website.
- Usage Data includes information about how you use our Website.
- Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
- Marketing and Communications Data includes your preferences in receiving direct marketing from us, i.e. 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 offences.
What do we use your Personal Data for?
We use your Personal Data for a variety of reasons, as listed below;
- If requested, register you as a Buyer;
- If requested, add you to our weekly newsletter and other email campaigns;
- If requested, add you to our Vehicle Alerts notification service;
- Process Purchases on your behalf;
- To carry out our obligations arising from any contracts entered into by you and us;
- Dealing with entries into a competition;
- Seek your views or comments on the Services we provide;
- Notify you of changes to our Services;
- Send you communications which you have requested and that may be of interest to you. These include our weekly email and other related marketing communication of interest;
- Personalisation of our advertising to you;
By completing a request for a valuation we will also add you to our weekly email update – this is relevant to you as it shows market valuations of vehicles and other information that could be useful for you when considering to sell your vehicle. You can unsubscribe at any time.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example for the purposes of financial records). We will hold your Personal Information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
Sharing your Personal Data
We will not sell or rent your information to third parties.
We may share Personal Data with the following categories of third parties:
- Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
- Auditors and professional advisers like bankers, lawyers, accountants and insurers; and
- Government, regulators and law enforcement.
We share Personal Data with the following specific third parties for the following purposes:
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
Data retention and deletion
We will only keep your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
Transfer to other countries
As part of the Services offered to you through this Website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your Personal Data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our Services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
In addition, if you linked to our Website from a third-party site, we cannot be responsible for the Privacy Policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Keeping your Personal Data safe
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised 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.
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
Contacting our Website
Users contacting this Website and/or its owners do so at their own discretion and provide any such Personal Data requested at their own risk. Your Personal Information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998.
Weekly email communication
We operate a weekly email communication, this is a key part of our Service and used to inform our subscribers about Auctions and Services supplied by us. Users subscribe when creating and Account through our online automated process. Users can also subscribe as a Buyer without having an Account and they can request it by directly contacting us by email, telephone or face-to-face, or by completing the sign-up prompts on our Website. Some subscriptions may be manually processed through prior written agreement with the User.
Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal Data relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No Personal Data is passed on to third parties (except our email service provider currently Mailchimp) nor shared with companies / people outside of the company that operates this Website. Under the Data Protection Act 1998 you may request a copy of Personal Information held about you. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this Policy.
Our email campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list]. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 Buyer Notification subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
Advertising on our Website
Users are advised to use Social Media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and Personal Data. We will never ask for personal or sensitive information through Social Media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
We may use social sharing buttons which help share web content directly from web pages to the Social Media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Our Social Media platform accounts may share web links to relevant web pages. By default some Social Media platforms shorten lengthy URLs. Users are advised to take caution and good judgement before clicking any shortened URLs published on Social Media platforms by this Website and its owners. Despite the best efforts to ensure only genuine URLs are published many Social Media platforms are prone to spam and hacking and therefore this Website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
You may seek approval, or if we think it is relevant to you, we may ask if you want to be added to our list of Buyers. This is a list of individuals or companies that have given us written or verbal consent to be contacted via their Contact Data when a Vehicle matching their preference is consigned by us, in order to offer the Vehicle for a Negotiated Sale.