ARROW COMMS PRIVACY POLICY (“POLICY”)

ARROW COMMS LIMITED (“ARROW COMMS”) is committed to protecting your privacy. This Policy applies to visitors of the Arrow Comms website at www.arrowcommsltd.co.uk (the “Website”).

This Policy sets out the basis on which any personal data that Arrow Comms collects from you or that you provide to Arrow Comms, will be processed by Arrow Comms. Please read the following information carefully to understand Arrow Comms’s views and practices regarding your personal data and how Arrow Comms will treat it.

All details supplied to Arrow Comms with your online advertisement will be safeguarded both by this Policy and also by the Data Protection Act 1998.

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 what information we collect. Please review this page regularly so that you are aware of any changes.

INFORMATION COLLECTED AND WHAT IT IS USED FOR

Arrow Comms may collect the following information about you:

Information you provide when you place an advertisement on the Website

As part of the advert placement process we will collect your name, email address and telephone number. We will also collect your postcode in order to provide a positioning of each vehicle within our database; this allows potential buyers to locate vehicles for sale within a set radius of a chosen location.

If your advert expires we will contact you via phone or email to give you the option to rebook your advert.

We use certain features to protect the privacy of our customers when they are communicating via phone or email. We mandate Protect Your Number on all adverts at the point of entering their phone number. Protect Your Number enables you to keep your telephone number private by providing you with a substitute telephone number to use in your advert. You will need to contact our Customer Service team if you wish to remove this facility Please be aware that if you opt out, your personal telephone number will be visible within your advert.

We supply a customer to customer email service that allows individuals who are viewing your advert to contact you via a link displayed on your advert, without exposing your email address. We use this to disable any potential harmful or spurious links that may expose you to fraudulent activity. The use of the customer to customer email service is mandatory for security provisions. We reserve the right to monitor and retain all communications via the email service for security monitoring purposes.

You will also be required to supply payment details and the vehicle registration number of the vehicle you wish to sell. Payment Card information is collected over a secure connection and all payment transactions will be encrypted. Payment Card information is used solely for the purpose of processing payment for your advert. Arrow Comms retains no record of Payment Card details.

Where advertising packages include additional benefits provided by third parties, we may pass your details on to these third parties to enable them to supply those benefits, provided that you have selected to opt in to receive information from third parties.

Information we request from you if you place an advert on the Website

If you place an advert on the Website, we will need to collect your email address to send you communications about how to access and manage your account (available within the “My Arrow Comms” section of the Website). You can access this area at any time in order to update your details or change your options regarding marketing communications from Arrow Comms and/ or selected third parties. Arrow Comms will only use your information for marketing purposes where you have agreed to this.

We collect information in order:

a) to generate an overall audience profile of visitors using the Website. This information is then used to assist in developing relevant content on the Website as well as ensuring that automotive trade advertisers looking to reach specific audience groups are encouraged to place their stock or promotions on the Website.

b) to provide customers who have supplied their insurance renewal date information and/or vehicle ownership details, with relevant and timely consumer offers by email.

c) to support our ‘Send to Mobile’ functionality – whereby visitors to our Website can send details of vehicles for sale to mobile phones.

d) to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

Vehicle Registration Numbers are required in order to place an advert on the Website. If you have opted in for 3rd party marketing then your vehicle registration number may be used to supply relevant offers and services including, without limitation, insurance quotations, vehicle history and credit checks, vehicle valuations and such other services as are developed by Arrow Comms from time to time. As part of the provision of these services, the third party authorised may need to disclose the Vehicle Registration Number to another third party for example, without limitation, an insurer, insurance panel or credit reference agency. Arrow Comms will not disclose the Vehicle Registration Number to any person carrying out vehicle searches on the Website, however, if he Vehicle Registration Number is displayed in photographs then the details are visible and non-approved other parties may use them.

Information you provide when requesting or using services on the Website

If you would like to book a test drive of a new car or bike, or to request a quote or brochure, we will require you to supply your name, email address, postal address and telephone number. Your contact details are collected to enable us to pass your details onto third parties who will contact you directly.

If you use the chat service to communicate with Dealers (“Chat Service”), you may disclose personal information in the course of using the service. All conversations and email exchanges are recorded. Any personal information that you disclose during a live chat or via an online form will be accessible to and processed by the third party supplier of the Chat Service and to the dealer with whom you communicate as well as being made available to ArrowComms.

Information we collect if you use our Mobile Applications

If you choose to download or use our Mobile Applications, or 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 manufacture of your particular device.

By submitting personal information to us, you are deemed to have agreed to the terms set out above regarding the use of your personal information.

Arrow Comms may also contact you for research purposes.

WHERE WE STORE YOUR PERSONAL DATA

Arrow Comms will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

All information (except Payment Card information) you provide to Arrow Comms is stored on Arrow Comms’s secure servers.

Once Arrow Comms has received your information, Arrow Comms will use strict procedures and security features try to prevent any unauthorised access.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to third parties as follows:

a) We will send your personal information to dealers, vehicle manufacturers, bike manufacturers and relevant third parties to enable them to provide you with the services and products that you have requested through the Website. In certain circumstances, vehicle manufacturers (including Ford Motor Company Limited) or bike manufacturers and other relevant third parties may transfer, process and store your personal information outside of the European Economic Area (“EEA”) for business and administration purposes. Additionally, the Chat Service provider may use computer infrastructure which is situated outside of the EEA.

By submitting your personal data to us through the Website, you consent to your personal data being transferred outside the EEA. By using the Chat Service, you consent to any personal data disclosed in the course of using the Chat Service being processed and stored by the Chat Service provider on its systems outside the EEA.

b) 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 (such as the ‘Facebook Recommend’ or Facebook Gestures’ function). 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. For more information on how these third parties use information, please read their privacy policies.

c) If we are under any 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.

d) In the event that Arrow Comms sells or buys any business or assets, in which case Arrow Comms may disclose your personal data to the prospective seller or buyer of such business or assets.

e) If Arrow Comms or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

f) Arrow Comms Limited may share your personal information with its group companies.

g) For the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any information that we collect with the Police, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation. This will include public authorities, insurance companies, finance companies, automotive advertising companies and/or other agencies.

MARKETING COMMUNICATIONS

When you register with our Website, we ask you whether you would like to receive our communications detailing offers, news and services from Arrow Comms and/ or information from third party companies via email and/or via post that we feel may be of interest to you. In order to receive these communications, you will need to opt in during registration.

On occasions Arrow Comms runs promotions in which personal information is collected. We will always ask you if you agree to this and advise you if this information may be shared with a third party. You will always be asked to provide your consent to this use by opting in.

To stop receiving Arrow Comms promotional offers and alerts, please click the link found at the bottom of each email or update your account preferences.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to third parties as follows:

a) We will send your personal information to dealers, vehicle manufacturers, bike manufacturers and relevant third parties to enable them to provide you with the services and products that you have requested through the Website. In certain circumstances, vehicle manufacturers (including Ford Motor Company Limited) or bike manufacturers and other relevant third parties may transfer, process and store your personal information outside of the European Economic Area (“EEA”) for business and administration purposes. Additionally, the Chat Service provider may use computer infrastructure which is situated outside of the EEA.

By submitting your personal data to us through the Website, you consent to your personal data being transferred outside the EEA. By using the Chat Service, you consent to any personal data disclosed in the course of using the Chat Service being processed and stored by the Chat Service provider on its systems outside the EEA.

b) 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 (such as the ‘Facebook Recommend’ or Facebook Gestures’ function). 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. For more information on how these third parties use information, please read their privacy policies.

c) 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.

d) In the event that Arrow Comms sells or buys any business or assets, in which case Arrow Comms may disclose your personal data to the prospective seller or buyer of such business or assets.

e) If Arrow COmms or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

f) Arrow Comms Limited may share your personal information with its group companies.

g) For the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any information that we collect with the Police, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation. This will include public authorities, insurance companies, finance companies, automotive advertising companies and/or other agencies.

MARKETING COMMUNICATIONS

When you register with our Website, we ask you whether you would like to receive our communications detailing offers, news and services from Arrow Comms and/or information from third party companies via email and/or via post that we feel may be of interest to you. In order to receive these communications, you will need to opt in during registration.

On occasions Arrow Comms runs promotions in which personal information is collected. We will always ask you if you agree to this and advise you if this information may be shared with a third party. You will always be asked to provide your consent to this use by opting in.

To stop receiving Arow Comms’s promotional offers and alerts, please click the link found at the bottom of each email or update your account preferences.

COOKIES

The Website uses cookies to distinguish you from other users. This helps Arrow Comms to provide you with a good experience when you browse the Website and also allows Arrow Comms to improve the Website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie policy.

ACCEPTANCE

By using the Website, you consent to the collection and use of this information by Arrow Comms and to this Privacy Policy.

CONTACT

Questions, comments and requests regarding this Policy are welcomed and should be addressed to enquiries@arrowcommsltd.co.uk