Dealer Auction Holdings Ltd and its subsidiaries (together “Dealer Auction”) is a UK wholesale digital automotive marketplace.

To provide you with the full range of Dealer Auction products and services, we need to collect and process information about you.

Dealer Auction Holdings Limited is part of a joint venture between the Cox Automotive UK and Auto Trader UK (together “the Parent Entities”). References in this privacy policy to the Parent Entities should be taken to include all of these companies:

If you wish to contact our Head of Privacy & Data Protection, you can do so by emailing ukca.dataprotection@coxautoinc.com.

Dealer Auction is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it. It’s important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.

This Privacy Policy explains:

• What information Dealer Auction collect about you;
• How Dealer Auction collects and uses information about you;
• Whether Dealer Auction discloses your details to anyone else;
• The choices available to you regarding the personal information you provide to us; and
• When and how your data may be shared with third parties.

Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.

We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended and the General Data Protection Regulations (GDPR).

Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by dealers.

Where you have given consent for Dealer Auction to process your personal data you may withdraw consent at any time by emailing marketing@dealerauction.co.uk. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.

If you have given consent for your details to be passed to a dealer or other third party your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.

We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:

• Contract: To enter into a contract with you and fulfil our contractual obligations to you (e.g. to publish your advert). This processing is necessary for us to provide the service you have requested such as registering, managing your account, and providing service updates and our support services.
• Legitimate Interests: To process the necessary information to facilitate services that do not require a contract between you and Dealer Auction. This is necessary for advertising your vehicle and communicating the outcome of certain auctions with you so that the sale can be progressed by you and the buyer.
• Consent: To provide information and take actions in relation to services which you have opted-in to receive.

We use the information we collect to:

• Enable the performance of the contract you are entering into when using our service;
• Facilitate the sale of your vehicle and ensure that all parties involved are communicated with as appropriate;
• Provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services;
• Generate an overall audience profile of visitors using the Website. We use this information to assist us in developing relevant content on the Website as well as encouraging automotive trade advertisers to place adverts for their stock or promotions on the Website; provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email;
• We share some of your information with the Parent Entities to enable us to build up a profile of which of our group companies you do business with and what products and services you obtain from us. This to help us build up a more complete understanding of our customers and to inform our decisions around issues such as marketing;
• Support our products and services such as alerting functionality;
• Provide a user-friendly online search experience. This includes the use of website analytics tools as described further in our Cookie Policy;
• Identify the location of visitors, to block disruptive or fraudulent use and to establish the number of visits from different countries.

Dealer Auction collects the following information when you set up an account:

1. Personal data including your name, address, email address, telephone number and mobile telephone number. This data is collected to register your account and place your adverts as well as to send you service communications about your account. We may share certain personal data, such as contact details, with dealers or individuals interested in purchasing your vehicles as part of our standard trading. Once you have registered you can edit your personal details in your account. If you log-in via Facebook or another social media account, those sites may automatically give us access to your limited personal details (including your account ID and email address) in order to verify if you are logged in with their site. Once you are logged-in to our Website in your use of the Website and your data will be handled in accordance with this Privacy Policy and the Cookie Policy. We are not responsible for any use of your personal data by Facebook or any other social media site.
2. Account numbers from other companies in the Parent Entity groups to understand the companies you are trading with and help with our marketing campaigns. We will only use your information for marketing purposes where you have given us specific consent.
3. We also collect additional personal data which may be generated as a result of the use of your account such as invoices and other records related to payments and transactions.

Dealer Auction collects the following information when you use our products & services:

As part of the advert placement process on the Website, we collect your postcode, as well as details of the vehicle you wish to sell, payment details (please see below) and your IP address. This information is used as follows:

1. Postcode: to provide a positioning of the vehicle you advertise. This allows potential buyers to locate vehicles for sale within a set radius of their chosen location.
2. Vehicle Registration Numbers are required to place an advert on the Website for regulatory and security purposes. If the Registration Number is displayed in photographs within your advert then these details may be visible to Website visitors who may use them without your authorisation.
3. We may also use the information you provide for internal business records and purposes, including to analyse and develop our products and services and the Website.

As part of the closed-network auction pilot, that we have partnered with Auto Trader on, your information is used as follows:

1. Once you have signed up to the pilot, Auto Trader will provide Dealer Auction with your name and contact details along with your vehicle information to enable the vehicle to be advertised on our platform.
2. Your contact details will be used by us to communicate relevant information and update you on the auction of your vehicle and any successful bids so that you can move forward with the buyer.

As part of our Remarketing Services, that we have partnered with Manheim on, personal information is used as follows:

1. Seller data will be passed to Manheim to enable Remarketing Services to be progressed and to facilitate contact regarding those services.
2. Where it is agreed that Dealer Auction will be responsible for removing any personal data left within the vehicle, this service will fall under the responsibility of Manheim.

If you choose to access one of our mobile optimised sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalised content. Most mobile devices allow you to control or disable location services within the mobile device’s settings. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your device.

All payment transactions processed are encrypted. Your payment card information is used solely to process payment for your advert, subscription, and fees. We retain no record of your payment card details.

Dealer Auction will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:

• Information may be shared with people employed by Dealer Auction and our Parent Entities where necessary for us to provide you with the products and services that you have signed up to receive.
• We use Auto Trader to handle sign up, invoicing and payments for certain services provided by Dealer Auction and so we will share certain personal data with them. In this context Auto Trader operate as a data processor acting on behalf of Dealer Auction.
• We have also partnered with Auto Trader to pilot a consumer to business closed network auction offering. We will send notification of successful sales back to Auto Trader via a secured API. In this context Dealer Auction and Auto Trader are working together as separate data controllers.
• We use Manheim to handle sign up, invoicing and payments for certain services provided by Dealer Auction and so we will share certain personal data with them in order for them to do this. In this context Manheim Ltd operate as a data processor acting on behalf of Dealer Auction.
• Manheim also act as our data processor when providing Remarketing Services on our behalf and we share personal data with them to enable the facilitation of those services.
• We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third-party platforms (e.g. Facebook). Information about your visit to the Website may be collected by these third-party providers on these pages. If you browse these pages whilst still also logged in to your account on the third-party platform, information collected by the third-party may be connected to your account on the third-party platform. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
• Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our terms and conditions and any other agreements.
• If we sell or buy any business or assets, in which case Dealer Auction may disclose your personal data to the prospective seller or buyer of such business or assets.
• We may share your personal information with our group companies.
• We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies, automotive advertising companies and other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and the apprehension or prosecution of offenders.
• You acknowledge that we have a legitimate business interest in preventing the use of our platform or services in any manner that may facilitate fraudulent activity or deny consumers of their legal rights under the Consumer Protection from Unfair Trading Regulations 2008 or the Consumer Rights Act 2015. We may share any information that we collect about you or the vehicles that you advertise for sale on our platform with third parties or their legal representatives to the extent necessary to conduct appropriate anti-fraud, money laundering and identity checks.
• We will share inspector, seller, and claimant details with the relevant third parties, in-line with our Remarketing Services, as part of the SureCheck process.

We are not responsible for any use of your personal data by these parties except where they act as our processor.

You have the following rights in relation to the personal information Dealer Auction processes relating to you. Where you exercise these rights, Dealer Auction will provide information to you as to what action has been taken, if any, within one month of receipt of your request. Where no action has been taken, Dealer Auction will explain our reasons why.

Considering the complexity and number of requests, it may take Dealer Auction up to 3 months to respond to your request. Where Dealer Auction intend to extend the deadline for responding, you will be informed within one month of receipt of your request.

If you would like to submit an Information Rights Request (IRR) please contact our Privacy & Data Protection Team at ukca.dataprotection@coxautoinc.com

You have the right to request access to the personal information that Dealer Auction hold about you.

Where personal information that Dealer Auction holds about you is inaccurate, you have the right to request that those inaccuracies are rectified. Taking into account the purposes for which the personal information is processed, you also have the right to have incomplete personal information about you completed.

In certain limited circumstances, you have the right to request that Dealer Auction erase personal information relating to you that Dealer Auction hold. This right only applies if any one of the following circumstances applies:

• Where Dealer Auction no longer require the personal information for the purpose(s) for which it was obtained or otherwise used.
• Where the processing is based on your consent, that consent has been withdrawn and there is no other legal ground for processing.
• Where you have exercised your right to object to the processing and there is no overriding legitimate grounds for the processing.
• Where you have exercised your right to object to the use of your personal information for direct marketing purposes.
• Where the personal information has been unlawfully processed.
• Where Dealer Auction are required to erase the personal information in order to comply with a legal obligation.

The right does not apply where the processing of your personal information is necessary:

• For compliance with a legal obligation requiring Dealer Auction to process your personal information or where the processing is necessary for the performance of a task carried out in the public interest
• For the establishment, exercise or defence of legal claims.

You have the right to request that Dealer Auction restrict the processing of your personal information in the following circumstances:

• Where you have contested the accuracy of the personal information. In this case the processing of the personal information will be restricted for a period which enables Dealer Auction to verify the accuracy of the personal information in question.
• Where the processing of the personal information is unlawful and you have objected to the information being erased and have instead requested the restriction of its use.
• Where Dealer Auction no longer needs the personal information for the purposes set out above but you require them for establishing, exercising or defending legal claims.
• Where you have objected to the processing of your personal information as set out above. In this case, processing of your personal information will be restricted pending verification of whether our legitimate grounds for continuing to process your personal information override your grounds for objecting.

Where processing of your personal information is restricted for any of the reasons above Dealer Auction will not process it, with the exception of storage, unless:

• You have provided your consent,
• For the establishment, exercise or defence of legal claims,
• For the protection of the rights of another natural or legal person, or
• For reasons of important public interest.

Where Dealer Auction have agreed to restrict the processing of your personal information, we will write to you to inform you that we will be lifting that restriction prior to doing so.

This right only applies in the following circumstances:

• Where the personal information in question consists of information you have provided to Dealer Auction,
• Where the grounds for processing the personal information stated above are consent, explicit consent or for the performance of a contract or to take steps at your request prior to entering into a contract, and
• The processing of the personal information is carried out via automated means.

Where this right applies, you have the right to receive your personal information in a structured, commonly used and machine-readable format. You also have the right to transmit that information to another data controller or, where possible, directly from Dealer Auction to another controller.

You have the following rights in relation to objecting to the processing of your personal information by Dealer Auction:

You have the right to object to the processing of your personal information at any time, on grounds relating to your particular situation. This only applies where the grounds for processing are:

The processing is necessary for the purposes of legitimate interests pursued by the data controller or by a third party, or

Processing is necessary for the performance of a task carried out in the public interest

You have the right to object specifically to the processing of your personal information for the purposes of direct marketing. If you object to the processing of your personal information in this way, then Dealer Auction will no longer process it for that purpose.

You have the right not to be subjected to a decision based solely on automated processing, including profiling which would legally affect you or significantly affect you. However, this right will not apply if the decision:

• Is necessary for the entering into, or performance of, a contract between you and Dealer Auction
• Is authorised by or under any law to which Dealer Auction is subject, or Is based on your explicit consent.

Where you believe that Dealer Auction has failed to properly comply with its obligations in respect of your personal information, including your rights as set out above, you can complain to the Information Commissioner.

The Information Commissioner’s Office’s address is:

You can find more information about their role and how to submit a complaint on their website: www.ico.org.uk.