We are Mobility Trader UK Ltd, trading as heycar. We refer to heycar as "we", "us" and "our". We operate the following sites:
For the purposes of UK and EU data protection law, (the "Data Protection Law"), the controller of the Service is heycar.
- Information we collect about you
- How we use your information
- Our promotional updates and communications
- Who we share your information with
- Where we store your information
- Public forums
- Child safety
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contacting us
Information we collect about you
We will collect and process certain personal information if you use our Service, including searching for used cars and getting in touch with our selected dealers.
We also process information about you:
- if you, or the company you work for, are a selected dealer of ours.
- if you or the company you work for use our Service generally.
- you are someone, or you work for someone, to whom we want to advertise or market our Service.
You provide us with
|This is information about you that you provide us directly when you use the Service, including if you:|
When you interact with us, we collect the following types of personal information:
Other parties may provide us with
We work closely with third parties (including car dealerships, car manufacturers, financing and insurance providers, sub-contractors in communications, technical, and payment services, advertising networks, analytics providers, and search information providers).
We may share personal information we collect within heycar (including our group companies and joint venture partners), or combine data from other sources with personal information you've given to us – for example, if you get in touch with a dealer as part of your search for your next car.
This may involve processing your identity, contact, interaction and finance information.
This may involve processing your work identity, contact, dealer interaction and finance information.
Personal information which is not collected directly from you may be collected:
We automatically collect
We will automatically collect information from you each time you use our Service. This includes:
How we use your information
We use your personal information in different ways. We've set these out below, along with the types of personal information we use for each purpose, and the legal reason(s) (also known as the 'legal basis') that permits this processing.
We explain more about what each legal basis means below. We may process your personal information based one or more than one legal basis, depending on the specific ways we are using your personal information.
|How we use this personal information||Type of personal information||Our legal bases for processing|
|To save searches and send you search alerts (for example, new listings which fit your search criteria).|
|To put you in touch with UK depots who may provide vehicle part information to you, the information you provide may be shared with 1st Choice Spares and depots across the country so they can contact you about the vehicle part(s) you are interested in.|
|To register you as a new user who wants to use our Service, if you choose to create an account. You don't need to have an account to search for vehicles on heycar.|
|To allow you to purchase a vehicle from a vehicle dealer through heycar or from heycar directly, including (as applicable):|
|To allow you to apply for financing with VWFS (or other financing providers)|
To promote our service to you and keep you updated with information about our services, including:
To ask you to leave a review, provide feedback or take a survey.
To offer you exclusive deals and offers.See Our promotional updates and communications to learn more
|To manage and administer promotions, competitions and prize draws which you enter, subject to their terms and conditions which will be notified to you when you enter, including collecting and checking entries, contacting winners, awarding and delivering any prizes, and complying with our regulatory obligations.|
To customise your experience and offer you relevant ads, content and recommendations including information about new promotions and competitions.
To deliver dynamic marketing and show you non-personalised ads on our website.
Social media integrations: Our marketing campaigns use Facebook's advertising and audiences tools, including tracking pixels, to inform and refine our marketing and deliver more relevant ads to you.
For measuring, understanding and optimising the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To administer our Service and for internal operations, including bug fixes, troubleshooting, data analysis, testing, and survey purposes.
To improve our Service to ensure that content is presented in the most effective manner for you and for your computer. We may also use aggregated information to help us plan and introduce new features.
To keep our Service safe and secure, including taking steps to detect and prevent fraud.
To analyse our user base, Service and service usage, feature and content popularity, software and hardware quality, and market trends.
To share aggregated and anonymised statistics with dealers and other organisations about how people use heycar, including in order to attribute leads. You cannot be identified from this information.
We may also use this information to inform, refine and deliver our wider online marketing campaigns, including delivering our advertisements to you when you are not on our Service.
|How we use this personal information||Type of personal information||Our legal bases for processing|
|If you work for one of our selected dealers, or are otherwise interacting with us in a business context, we may also use your personal information for the following purposes.|
|To perform or enter into any contract we have with you|
To administrate yours or your company's accounts with us.
To make and verify payments and bills.
In the event that we sell or buy any business or assets, disclose your data to a prospective seller or buyer, or in the event we are the subject of acquisition by a third party.
To answer any queries you send us
To comply with any rights requests you make
Where we receive your personal information from a third party, they will be a separate data controller of your personal information, and will have their own legal bases for processing.
Our promotional updates and communications
Where permitted in our legitimate interests (explained below) or with your prior consent if required by law, we may
- send you marketing and promotional updates about our products and services, by email and SMS, if you have opted-in to receiving these.
- use your work contact information, if you work for a dealer, to send you marketing and promotional updates about our products and services, by phone, email and SMS, unless you have opted out of receiving these.
- we will also use your personal information for marketing analysis.
You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to email@example.com.
Who we may share your information with
We may give your information to:
- Any member of the heycar group, which means our shareholders, investors, subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal information under this policy. If any of these parties use your information for direct marketing, we will only transfer it to them for that purpose with your prior consent.
- Our partner and support businesses, including support services, finance lenders, advertising networks, prize draw or competition partners, and analytics providers, as well as car dealers and depots (only if you ask for more detail about a car or vehicle part, or to be put in touch with them).
Our selected third parties may include:
Dealers and depots who, if you ask us to, we will share your information with in order for them to contact you about the car, vehicle part or other request you submitted.
- Dealers: if you enquire about a vehicle, we will share your information with the dealer of that vehicle.
- Depots: if you enquire about a car part, will share your information with 1st Choice Spares UK Ltd and depots across the UK.
Financing providers (like VWFS) who, if you apply for financing, we will share your application information with so you can apply for and arrange PCP or HP financing when you buy a vehicle.
Organisations who process your personal information in order to provide a service to us. This includes third party suppliers, agents, sub-contractors and/or other companies in our group who support the services we offer through the Service, including those:
- providing website and data hosting services,
- providing fulfilment services,
- distributing any communications we send,
- supporting or updating marketing lists,
- facilitating feedback on our services, and
- providing IT support services.
Advertisers and advertising networks that require the data to serve our adverts to you across other websites.
- We don’t disclose identifiable information about you to our advertisers. We provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 30 have clicked on their advertisement on any given day).
- We may use the personal information we collect from you to enable our advertisers to display our ads to people we think might be interested.
See our Cookies Policy for more information.
- Prize draw or competition partners to the extent required to administer and manage prize draws or competitions, including contacting winners and awarding any prizes.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site (this will not identify you as an individual). Interested. See our Cookies Policy for more information.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will also share your personal information with third parties:
- If heycar or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
- If 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 or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of heycar, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Where we store your information
We may transfer and store your personal information outside the United Kingdom ("UK") and/or European Economic Area ("EEA") in countries which may not have equivalent Data Protection Law.
We may transfer your personal information outside the UK or EEA:
- In order to store it.
- In order to enable us to provide our Service to you and fulfil our contract with you. This includes the provision of support services, including our concierge chat service and other customer service support.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
We may transfer your personal information to the following countries and using the following safeguards outside the UK or EEA:
|BCG Digital Ventures||Standard Contractual Clauses|
Amazon Web Services, Inc.
|Standard Contractual Clauses|
|The Rocket Science Group LLC d/b/a MailChimp||Standard Contractual Clauses|
|MailChimp||Standard Contractual Clauses|
|Intercom, Inc.||Standard Contractual Clauses|
|Facebook, Inc.||Standard Contractual Clauses|
|Google LLC||Standard Contractual Clauses|
|Hubspot, Inc.||Standard Contractual Clauses|
|Twilio Inc.||Standard Contractual Clauses|
|Aircall||Standard Contractual Clauses|
Protecting the safety of children when they use the Internet is important to us.
The Service is intended for use only by persons who are at least 18 years of age.
By using the Service, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using this site/App or sending us personal information.
If you are under the age of 18 your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information.
How we protect your information
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Service, you are responsible for keeping this password confidential. We ask you not to share a 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 information, including using SSL encryption to secure our site and protection your information in transit We cannot guarantee the security of your data transmitted to the Service; 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.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We keep personal information for
- as long as you have an account with us or use our Service (including if you enter a prize draw, competition or other promotion) in order to meet our contractual obligations to you and
- six years after that to identify any issues and resolve any legal proceedings.
We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
You have the right under certain circumstances:
- to be provided with a copy of your personal information held by us;
- to request the correction or erasure of your personal information held by us;
- to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal information, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section;
- to request that your provided personal information be moved to a third party.
- Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org. You can also change your marketing preferences at any time as described in Our promotional updates and communications section;
You can also exercise the rights listed above at any time by contacting us at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information.
Changes to this policy
30 Broadwick Street, London W1F 8JB