1. Who we are
57 Spring Gardens, 38-54 Mosley Street,
Manchester M2 3AZ
- Cox Automotive UK Ltd
- Cox Automotive Retail Solutions Ltd
- Manheim UK Ltd
- Nextgear Capital Ltd
- Dealer Auction Ltd
- Money4yourmotors.com Ltd
- Movex Logistics Ltd
- Kingfisher Systems Ltd
- RMS Automotive
- Modix UK Ltd
- Manheim Vehicle Services
If you wish to contact our Head of Privacy & Data Protection, you can do so by emailing firstname.lastname@example.org.
2. What we collect & what we do with your personal information
eVA collects and uses personal data relating to you for the following purposes and on the following grounds:
When you sign up for Cox Automotive Products or Services we will collect data in order for us to create and administer your account. We will obtain some or all of the following information to enable us to process your request:
- Email address
- Phone number
- VAT number
- Company or Trading name
List of Directors, Owners or Partners of the business
We use IP addresses for two reasons:
- To determine whether activity on our domains has been carried out by ‘human’ activity as opposed to bot or crawler activity.
- For research purposes in order to help us understand consumer activity and search trends on our network.
We may also share your name and contact details with other members of the Cox Automotive Group for the purpose of sending you direct marketing communications if you have expressed consent for us to do so.
We retain a log of your correspondence with us including emails, online chat sessions and telephone calls. We retain any personal data contained within these communications for the purposes of providing an audit trail of your interactions with us. Recordings of telephone calls are retained for 90 days and recordings of emails are retained for 2 years.
2.1 Grounds on which we process your personal data
eVA processes your personal information on the following grounds:
- Performance of a contract
- eVA provides various data products and services. Where you use one or more of these products and/or services you are entering into contract with eVA in relation to the use of our products and/or services. We process the personal data collected in order to administer these products and services.
Where we process your personal data for direct marketing purposes, whether for the purpose of sending such communications or sharing with the Cox Automotive Group for such purposes, is based on us having contained valid opt in consent from you to do so.
You have the right to withdraw your consent at any time though this does not affect the lawfulness of the processing of your personal information prior to that withdrawal. You can withdraw your consent by visiting your preference centre.
2.3 Legitimate Interests
Where it is not necessary for us to process personal data for the performance of our contract with you, such as the correspondence logs, then this personal data is processed on the basis of eVA or the third party to whom we provide the data pursuing legitimate business interests.
It is in our legitimate interest to maintain audit logs of communications between eVA and clients. This is to assist in quality monitoring purposes and in order for us to demonstrate the value of our service to our clients.
Processing undertaken for any other purpose set out in section 2 above which has not otherwise been specifically dealt with here is processed on the basis of legitimate interests. It is in the legitimate interests of both eVA and the Cox Automotive Group to understand the activities of those who use our products and services, including websites, to ensure that activity is being undertaken is legitimate, i.e. it is being undertaken by an authorised source.
3. Disclosures and Transfers
eVA will or may pass your personal information on to the following recipients:
- Staff of eVA or staff members of those who process personal data on behalf of eVA as set out in this section.
- Other members of the Cox Automotive Group.
- Please visit our sub processors page to review our service hosting and processing locations, including applicable affiliate and third-party sub-processor disclosures.
4. Your rights in relation to your personal information
You have the following rights in relation to the personal information eVA processes relating to you. Where you exercise these rights, eVA will provide information to you as to what action has been taken, if any, within 30 calendar days of receipt of your request. Where no action has been taken, eVA will explain our reasons why.
Taking into account the complexity and number of requests, it may take eVA up to 90 calendar days to respond to your request. Where eVA intend to extend the deadline for responding, you will be informed within 30 calendar days of receipt of your request.
4.1 Right of Access
You have the right to request access to the personal information that eVA hold about you.
4.2 Rights in relation to inaccurate personal information
Where personal information that eVA 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.
4.3 Right to erasure
In certain limited circumstances, you have the right to request that eVA erase personal information relating to you that eVA hold. This right only applies if any one of the following circumstances applies:
- Where eVA 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 have been unlawfully processed.
- Where eVA 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 eVA 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.
4.4 Right to restriction of processing
You have the right to request that eVA 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 eVA 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 eVA no longer needs the personal information for the purposes set out in part 2 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 in section 3.6.1 below. 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 eVA 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 eVA 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.
4.5 Right to data portability
This right only applies in the following circumstances:
- Where the personal information in question consists of information you have provided to eVA,
- Where the grounds for processing the personal information stated in section 2 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 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 eVA to another controller.
4.6 Right to object to processing
You have the following rights in relation to objecting to the processing of your personal information by eVA:
- You have the right to object at any time, on grounds relating to your particular situation, to the processing, and
- The right to object specifically to the processing of your personal information for direct marketing purposes.
4.6.1 Right to object to processing
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
4.6.2 Right to object to processing for the purposes of direct marketing
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 eVA will no longer process it for that purpose.
4.7 Rights in relation to automated decision making & profiling
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 eVA
- Is authorised by or under any law to which eVA is subject, or
- Is based on your explicit consent.
4.8 Right to complain to the Information Commissioner’s Office
Where you believe that eVA has failed to properly comply with its obligations in respect of your personal information, including your rights as set out in section 3.1-3.7 above, you can complain to the Information Commissioner.
The Information Commissioner’s Office’s address is:
The Information Commissioner’s Office Wycliffe House
You can find more information about their role and how to submit a complaint on their website: www.ico.org.uk.