Privacy Policy

What this document is and why you should read it

This policy outlines how we, Exchange My Car Limited (also referred to as “Exchange My Car”, “EMC”, “exchangemycar.co.uk”, “the Website”, “we”, “our” and “us”), uses personal data about individual users of our website www.exchangemycar.co.uk (the Website), and those that access our services such customers and/or professionals, including through APIs and third-parties (whether prospective, current or past) (together, “you”).
We use the personal data we collect for a number of different reasons, including to provide our services to you or with you, to communicate with you, to make sure our website and services are functioning properly and provide the best services for you, to keep accurate records and for legal reasons.

 

1. What category of individual you fall into

2. Personal data we collect and where we get it from

Sources of personal data
Category	Types of personal data	Collected from
Customers	Basic data Communication data Vehicle data Account data Enquiry/order data Website data Geolocation data Analytics data	You The Website (including any cookies) Your device Third party sources, including social media, vehicle data suppliers, search engines, online maps, online marketplaces, online customer review sites and directories
Professionals	Basic data Communication data Account data Professional data Website data Geolocation data Analytics data	You Your employer The Website (including any cookies) Your website Your device Third party sources, including social media, vehicle data suppliers, search engines, online maps, online marketplaces, online customer review sites and directories
Website Users	Basic data Communication data Website data Geolocation data Analytics data	You Our Website (including any cookies) Your device

 

Types of personal data
Category	Types of personal data
Basic data	Basic contact information and identity information (including name, postcode, email address and phone number)
Communication data	Communications we may have with you or other information which you may voluntarily provide, including images, videos or documents you may upload as part of a enquiry or service request Your contact/marketing preferences
Vehicle data	Information about your vehicle (including registration number, mileage, description of condition and other specifications)
Account data	Profile generated from enquiries and its details User names, passwords and other log-in information Activity history and referral data Analysis we may undertake on account usage from time to time Billing details, including card details and billing address
Enquiry/order data	Your draft, actual and suggested request(s), search request(s), enquiries made, and correspondence Feedback on the Website usage for Customers and feedback, comments and ratings of Professionals
Website data	Information about your device, which may include the device’s IP address, browser type, browsing history, preferences, identification numbers, your mobile carrier, date and time stamps and other interactions with the service Questions raised with us Information you provide us when you visit the Website
Geolocation data	Your device and/or the information you give us might tell us your approximate geographical location
Analytics data	Information to monitor and analyse use of our services, for example for our service’s technical administration, to increase our service’s functionality and user-friendliness, and to verify users have the authorisation needed to process their requests
Professional data	Details about the service(s) you or your employer provide Payment records and bank account details Partner profile Performance analysis we may undertake from time to time Account details and activity history User names, passwords and other log-in information

 

3. Who processes your personal data

 

We, Exchange My Car Limited, are the data controller of the personal data that you provide on the Website and/or that we collect about you. This means that we are the company responsible for deciding how your data is processed.
The personal data you provide us will be passed to Partners and suppliers, or any third party that provides a service that you enquire about or request through us. In any case, we do not share your data with parties outside the EEA.
Partners you are introduced to as a result of your enquiry or request for a service also become Data Controllers of your personal data and are independently responsible for how they process your personal data.
It is important you are aware of how they will process, store and share your data. To facilitate this, we have included links to the Privacy Policies of current Partners below.

Requesting our services: to sell or value a vehicle

In order to provide you with a vehicle valuation or sale services advertised on the Website and/or to respond to a related enquiry you raise, we need to pass your personal data to our Partners. This is so that they can assist you with your enquiry and/or request directly.  The following is a list of Partners you may be introduced to when you request or enquire about a vehicle valuation or vehicle sale services:

Bapchild Motoring World (Kent) Limited Trading as Big Wants Your Car https://bigwantsyourcar.com/privacy-policy/
Digital Automotive Solutions Limited trading as The Car Buying Group https://thecarbuyinggroup.co.uk/privacy
G3 Remarketing Ltd trading as Car Buying Crew https://www.carbuyingcrew.co.uk/privacy/
MONEY4YOURMOTORS.COM LIMITED https://www.money4yourmotors.com/privacy-notice/
CarTakeBack.com Limited https://www.cartakeback.com/privacy-policy/
Axis Dealer Ltd trading as Sell Your Car in a Flash https://www.sellyourcarinaflash.com/privacy
Motor Dough Limted https://www.motordough.com/privacy-policy/
Peter Cooper Motor Group Limited https://www.petercoopergroup.co.uk/site/privacy-policy/
Peter Vardy Limited trading as GoodBye Car https://www.goodbyecar.uk/our-policies/privacy-policy
Hippo Vehicle Solutions Limited trading as Hippo Car Sell https://hippocarsell.co.uk/privacy-policy/
New Reg Limited trading as Car.co.uk https://www.car.co.uk/privacy-policy
Samuel Thomas Johnson trading JST Automotive https://www.jstautomotive.com/privacy_policy/

Requesting our services: to find information about a vehicle

We are the Data Controllers of the personal data you provide to request the below information about a vehicle:

1. MOT history
2. ULEZ compliance
3. Tax status
4. Vehicle history

We anonymise your personal information and share only your vehicle registration number with UK-based third party data providers that help us to provide the service on request. These third parties provide us with database information; analytics services; or IT processing and data storage services.

Requesting our services (other third parties)

We may need to share your personal information with other organisations or people. Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers.
These organisations may include:

1. Suppliers: such as IT support services, payment providers such as Stripe, vehicle data providers, Government data services such as API’s from TfL and the DVLA, administration providers, marketing agencies.
2. Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies.
3. Our advisors: such as lawyers, accountants, auditors, insurance companies.
4. Email Platforms: such as Sendgrid.
5. Any organisations which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser.

4. What we use your personal data for (Purpose and Lawful basis)

 

Purpose	Lawful basis for using your personal data
Website users, Customers and Professionals
Corresponding with you, responding to your requests, enquiries and/or complaints	Contract performance Legal obligation Legitimate interests (to respond to you in relation to such matters)
Confirming and processing enquiries that you may make with us	Contract performance Legitimate interests (to process your orders)
Confirming and processing purchases that you may make with us	Contract performance Legitimate interests (to process your orders)
Sending you service information (including direct marketing)	Consent (direct marketing) Contract performance (service updates) Legitimate interests (to keep you updated on requests with other helpful updates and direct marketing in other cases)
Ensure and improve the operation and performance of the Website	Legitimate interests (to ensure the Website functions correctly and improve its functionality for the benefit of Website users)
To monitor and analyse use of our services	Legitimate interests (to provide relevant services to you and to optimise your experience)
To facilitate set up and use of your account	Contract performance Legitimate interests (to grant you access to your account where you can securely and easily access information relevant to you)
To understand and analyse how users engage with and use our services	Legitimate interests (to personalise and improve your experience and to better understand your needs and interests)
Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity	Legal obligation Legitimate interests (to fulfil our contractual obligation where you represent your employer or organisation)
Complying with requests, orders and instructions from law enforcement agencies, regulators, any court, parties to proceedings or otherwise deal with obligations required by law or regulators and to ensure good governance and compliance	Legal obligation Legitimate interests (where not binding but good governance and in the public interest)
For our general record-keeping and relationship management	Contract performance Legitimate interests (where you represent your employer or organisation)
To keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws	Legal obligation
Managing the proposed sale, restructuring or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation	Legitimate interests (to sell any part of our business)
Resolving any complaints from or disputes with you	Contract performance Legitimate interests (to try and resolve any complaint or dispute you might raise with us and to deal with legal claims)
Customers and Professionals
To deal with your request for a service	Contract performance Legitimate interests (to fulfil our contractual obligation where you represent your employer or organisation)
To recommend suggested searches to you	Legitimate interests (to encourage you to use our services)
To take payment from you or the business you represent or to receive services from you or the business you represent, to deal with any complaints	Contract performance Legitimate interests (to perform the contract where you represent your employer or organisation)
To share feedback and statistics on Professionals with potential Buyers	Legitimate interests (To share feedback and statistics on Professionals with potential Customers)
To enable Professionals to provide their services through our website and otherwise to Customers who have submitted enquiries to us	Legitimate interests (to enable Professionals to provide their services)
To onboard you as a Buyer and/or Professional	Contract performance Legitimate interests (to be able to offer you services and, where applicable, enter into a contract where you represent your employer or organisation)

5. What happens if you do not provide your personal data?

We need your personal data to process your enquiries and service requests. If you do not provide us with your data, we may not be able to provide you with our services.
We kindly ask that if you do not consent to us using your information, you do not request a quote, a service or make an enquiry via Exchange My Car.

 

6. How long will we store your personal information?

 
We will only keep your personal data for as long as is necessary for the purpose for which we need personal data. We are committed to ensuring your data is kept secure so we review our security systems on a regular basis. This is to enable us to refer to our records for the purpose of contract performance, legitimate interests, legal obligations, accounting or for statistical reasons.
If you have consented to receiving marketing communications from us, we will store your personal information for marketing purposes until you unsubscribe from receiving marketing communications from us.

 

7.  Your rights to your personal information

 

Right to access

 
You have the right to request copies of the personal information we hold about you at any time.

Right to rectification

 
You have the right to request that we correct any inaccurate personal information we hold about you.

Right to erasure

 
You have the right to request that we delete your personal information from our records. Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed, if we are able to do so while still abiding by law.

Right to restrict processing

 
You have the right to request that we restrict how we use your personal information.

Right to object

 
You have the right to object to the collection and use of your personal information at any time.

Right to data portability

 
You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.

Right to be informed

 
You have the right to be fully informed regarding your information throughout our whole journey.

Rights in relation to automated decision making and profiling

 
If a decision has been made electronically, you have the right to contest this decision.

8. How you can exercise your rights in relation to your personal information

 

You can exercise all of your rights by contacting us on any of the following contact details:

1. support@exchangemycar.co.uk
2. karina@exchangemycar.co.uk

 

9. How you can lodge a complaint about the use of your personal information

 

1. You can lodge a complaint with us directly by contacting us on one of the above contact details.
2. You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO).
3. The ICO is the regulator who makes sure that we use your personal information in a lawful way.
4. You can lodge a complaint with the ICO by following this link​https://ico.org.uk/concerns/​ or calling the ICO on 0303 123 1113.

 

10. Cookies

 
Our site may operate cookies and it’s important for us to make you aware how these are used so please do ensure you are aware of our Cookies Policy which can be found on our site.
You will be asked if you agree to these cookies when using our site, you have the right to refuse these Cookies.

 

11. Review

 
This policy will be reviewed on at least an annual basis and was last updated on 02.07.2024. Any updates will be reissued as soon as is physically possible with the approval of our Director and Senior Management team.

12. Contact us

Please note that for the purpose of holding personal data, we are registered with the Information Commissioner's Office, registered number: ZB525460
If at any time, you have any questions regarding how we use your information or this policy, please use the below details to contact us:
FAO Karina Freitas

1. Telephone: 01992 352 001
2. Email: karina@exchangemycar.co.uk
3. Address: Manufactory House, Bell Lane, Hertford, England, SG14 1BP