Privacy Policy

Introduction

Carket respects your privacy and is committed to protecting your personal data. This Privacy Policy gives information on how we obtain, keep, process, share and look after your personal data when you visit our website(s) or use our Services, as set out in our Terms & Conditions. This policy also explains your rights and how the law protects you.

Please, find the Definitions section below to understand the meaning of some of the terms used in this Privacy Policy.

About us and how to reach us

We operate a digital platform that facilitates the sale of used vehicles between private sellers and buyers. Servicefy Ltd trading as Carket is the controller and accountable for your personal data (collectively referred to as Carket, we, us or our as set out in this policy. If you have any questions about this policy or how we handle your personal information, please contact us on privacy@carket.co.uk or visit our Support section on our website.

We are registered with the Information Commissioner’s Office, and you have the right to complain to them should you find that we have not satisfactorily processed your personal data in line with this policy, our regulatory obligations or your legal rights.

If you have further questions you may have in relation with this policy or if you wish to update your preferences or exercise the legal rights you have, you can do so by writing to privacy@carket.co.uk and setting the subject line to "Data Privacy Preferences". The person in charge of data protection will respond to your query as quickly as possible.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Carket collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to use our Services or to receive our newsletter or you provide your permission for us to market to you about our services or goods/services provided by third parties we work with – this may include rewards we may offer through the use of our Services.

It is essential that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This Privacy Policy supplements the other policies and is not intended to override them.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Data collected and how we use it

Carket obtains the following data:

Data we may collect and process from you as a Seller or Buyer accessing the Website(s) or Services

  • "Registration Information" - Information provided by you at the point of registration or as part of your profile. Only registered users can use our Services to list a vehicle for sale or buy a vehicle on the website. To register, sellers are required to provide their name, email, phone number, details of the vehicle you intend to sell, postcode, payment details (please see below), and create an account password. To register as a buyer, you need to provide your name, email, phone number, and create an account password. Carket partners with numerous third-party vendors to deliver its Services. In some instances, the user’s data will be collected and stored by Carket’s third-party vendor and not by Carket, and the user will be subject to the privacy policy of Carket’s third-party vendors. We use your Registration Information for all purposes required to ensure the regular operation of your account and/or functionality of our Services, as well as to improve the Website and our Service;

  • "Financial and Transaction Information" - data you provide (includes payment card details, bank account and loan application details) to process payment for vehicle listing, secure funding for vehicle purchase and pay-out for the vehicle via Escrow Service. Carket does not retain any record of your payment card details. All payment transactions processed are encrypted to comply with regulatory and legal obligations. Your payment card information is used solely to process payment for your vehicle listing. The bank details in solely to process the remittance of the vehicle sale. While the loan application details are solely to process credit decisions and proceeds. The Financial and Transaction Information is collected and processed by third-party vendors over a secure online payment gateway provided by:

  • "Identity Information" - data you provide to conduct an identity check. To complete a Sale Transaction, both Sellers and Buyers are required to provide personal information such as title, date of birth, gender, residential address and government ID documents (in some instances) that Carket and its partners use to process identity verifications. In some cases, the user’s information will be collected and stored by Carket’s third-party vendor and not by Carket, and the user will be subject to the privacy policy of Carket’s third-party vendor;

  • "Usage and Web Access Information"- accessing our Services through our Website means we may collect specific data automatically and save it in log files. We collect technical data when you use our Services. This information includes (i) Device Information, Usage Data and Geolocation Information, (ii) details about your interaction with our website(s) and another Carket User including communications, payments, reviews, customer services communications (iii) other information of products and services which are linked to payment transactions including any description and any pictures you provide or upload as part of our functionality to use the Services we offer, and (iv) funding instruments used to complete transactions, your experience and behaviour information in interacting with us, other Carket Users and our website(s) primarily to improve your experience when using the Services. We may use cookies and other technologies which help us better understand user behaviour by telling us which parts of our Website people have visited and therefore enable us to improve the usability, performance and effectiveness of our Website. When you visit our Website, we may also collect so-called ‘clickstream’ data, such as domain names and page views. This information will enable us to analyse and better customise your use of the Service. If you do not want this data to be collected through the use of cookies, you can revoke the use of cookies in your browser. However, there may be some features of the Service which need the use of cookies to customise the presentation of information to you;

  • "Marketing and Communications Information" - includes contact details (email and telephone) to give you status updates about our Service communications and your preferences in receiving marketing from us and our third parties partners and your communication preferences. You can access "Your Dashboard" section at any time to update your details and can also change your options regarding marketing communications from us and/or third parties that you have selected in this area. We will not use your information for marketing purposes unless you have given us specific consent.

How we collect your personal data

We use various ways to collect data from and about you including through:

Direct interactions - involves filling in forms on our website(s) or by corresponding with us via post, phone, email or otherwise, you may provide your Identity, Profile and Contact Data and Financial and Transaction Data.

This information includes personal data you provide when you:

  • Use our Services;

  • Make any enquiries about us or our Services;

  • Create an account on our website;

  • Subscribe to our Services, communications or publications;

  • Request marketing to be sent to you;

  • Enter a competition, promotion or survey;

  • Interact with our Customer Services; or

  • Give us some feedback.

Automated interactions/technologies - when you interact with our website(s), we may automatically collect Usage and Web Access Information and Technical Data about your device, browsing actions and trends. We collect this data by using cookies, server logs, third-party and other alike technologies, for example, website(s) analytics providers. We may also receive Usage and Web Access Information and Technical Data about you if you visit other websites applying our cookies. Please see our cookie policy for further details.

How we use the data we collect

Under data protection regulations in the EEA (European Economic Area), we may process your personal data for many reasons that are justified and are permitted. This permission forms the legal basis on how we process your personal data. In most cases, we will use your personal data in the following cases:

  • To operate the website(s) and provide the Services to you and other Carket Users including:

    • fulfilling our obligations arising from any contracts entered into between you and us and to provide you with the information that you may inquire from us;

    • to furnish you with information about other vehicles and services we offer that are comparable to those that you have already purchased or enquired about;

    • to maintain, protect and enhance our site;

  • To operate our business needs, such as monitoring, analysing, protecting the integrity and enhancing the Services offered and provided to you and other Carket Users, and improving the Services and the website(s) performance and functionality. For example, we analyse Carket User behaviour and interaction and perform research about ways you use our website(s) and our Services;

  • To manage risk and protect you and other Carket Users from possible fraudulent activities, for example by verifying your identity, banking, payment and other financial details, products and goods subject to any transaction(s) and helping to detect and prevent financial crime, attacks and abuse of our website(s) and Services;

  • To comply with our obligations and to enforce the legal agreements relating to the use of our website(s) and the Services, including to comply with all applicable local and international laws and regulatory bodies such as the FCA;

  • For our legitimate interests including:

    • Allowing us, other third parties and legal enforcement bodies who have a legitimate interest, to enforce the legal agreements relating to our website(s) and our Services;

    • Where we need to comply with legal and regulatory obligations.

Marketing

We endeavour to provide you with choices regarding personal data uses, particularly around marketing and advertising. With your permission, we may:

  • Communicate with you by delivering marketing materials about Carket products and Services and any products and services of unaffiliated third party companies. To better match our understanding of how you use our Services or match your interests, we may process your personal data to tailor the Services or website experiences;

  • Provide you with location-specific offers, services, promotions, search results advertising and other personalised content. Likewise, we may use location-specific or geolocation functionality through the Services to improve the security of our website(s) and the Services, including ensuring we are offering the Services in the right locations;

  • Provide personalised services offered by Carket on third-party websites and online services. We may use your personal data and other data collected under this notice to provide targeted displays, feature or offer to you on our or third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third parties such as advertising or analytics companies to provide these services.

You have the right to revoke consent to marketing at any time. You have the privilege to do this by updating your preference through our website(s) or mobile application, or you can contact privacy@carket.co.uk.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites place or access cookies. If you disable or reject cookies, please note that some parts of our website(s) and Services may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy in The Legal section of our website.

Disclosures of your Personal Data

Carket will not share your personal data with third parties except as set out in this policy or with your consent. We may have to share your personal data or other information about you with others in a variety of ways as described in this section. We may share your personal data or other information for the following purposes:

  • With other parties to transact or facilitate our Services, such as other Carket Users, dispute resolution providers, merchants and other third-party service providers or website(s) who have integrated our Services. We may share information with the other Carket Users you are selling or buying a vehicle from, and merchants and other third-party service providers or website(s) who have integrated Carket Services you use to pay for goods or services, or independent dispute resolution service providers. This information includes:

    • Personal data required to facilitate the transaction;

    • Personal data to help resolve disputes and detect and prevent fraud; and

    • Anonymous data and performance analytics to help selected third parties to help them better understand the uses of our Services and help you, other Carket Users and other third party provides or website(s) who have integrated our Services to help enhance user experience;

    • With our partners that provide services to us. We share personal data with third-party service providers that perform services and functions at our direction and on our behalf to be able to make available our website(s) and Services. These third-party service providers may also provide you with our Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, provide customer support; to monitor your interactions with our website(s) and other Carket Users;

    • Other entities in our group of companies. We may share your personal data with members of the Carket family of entities to, among other things, provide the Services you have requested or authorised and to help us manage the availability and connectivity of Carket products, website(s), Services, and communications;

    • With other third parties for our business purposes or as permitted or required by the law. We may share data about you with other parties for Carket's business purposes or as permitted or required by law, including:

      • If we need to do so to comply with a law, legal process or regulations;

      • To law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Carket or Carket’s corporate family;

      • If we believe, in our sole discretion, that the disclosure of personal data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

      • To protect the vital interests of a person;

      • With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;

      • To investigate violations of or enforce Terms & Conditions or other legal terms applicable to any Services;

      • To facilitate a purchase or sale of all or part of Carket’s business;

      • To companies that we plan to merge with or be acquired by; and

      • To support our audit, compliance, and corporate governance functions.

Where your personal data stored

Carket will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. All information you provide to us is stored securely within the EU, and not transferred outside the EEA unless specifically detailed.

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. Also, 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.

Data retention

We will only retain your personal data for as long as required 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.

In some circumstances you can ask us to delete your data: see Right to be Forgotten below for further information.

In some circumstances, we may anonymise 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.

Your rights as a data subject

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at privacy@carket.co.uk or visit the Support section of our website for more information.

Here are your legal rights:

  • Right of access – you have the right to request a copy of the information that we hold about you. In the event that Carket refuses your request under rights of access, we will provide you with a reason as to why

  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

  • Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.

  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

  • Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organisation.

  • Right to object – you have the right to object to certain types of processing such as direct marketing, automated processing or profiling.

  • Right to complain to the regulatory authority – you have the right to complain as outlined above- see About Us & How To Reach Us.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes to our business, the website(s) or Services, or applicable laws. The revised Privacy Notice will be effective as of the published effective date.

If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on our website. We also may notify Carket Users of the change using email or other means.

Definitions

“Carket Users”- means an individual who makes use of the Services or accesses the website(s) and has established a relationship with Carket as a buyer, seller or another type of participant to a transaction.

“Device Information”- means data that can be automatically collected from any device used to access the website(s) or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the website(s) or Services.

“Geolocation Information”- means data that identifies, with reasonable specificity, your location by using, for instance, postal code, longitude and latitude coordinate obtained through GPS or WiFi, your IP address or cell site triangulation.

“Information Commissioner’s Office”- means the UK regulator for the protection of personal data and electronic communications also known as the ICO. You can contact the ICO in writing at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF United Kingdom, or by visiting their website at www.ico.org.uk.

“Legitimate interest”- means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

“Personal Information”- implies any information that identifies or can be used to identify you directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, payment card number, other financial account information, account number, occupation, government-issued credentials (e.g., driver’s license number, national ID, passport number)or other demographic information.

“Process”- means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.

“Services”- mean any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Servicefy Ltd trading as Carket, under the Terms & Conditions.

“Website(s)”- means the websites, mobile apps, official social media platforms, or other online properties through which Carket offers the Services and which has posted or linked to this policy.

“Usage Data”- means data we obtain from your device that you use to access the website(s) or Services. Usage Data tells us how you use the website(s) and Services, such as what you have searched for and viewed on the site(s) and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the website(s) and other usage and browsing information collected through Cookies.