Free Trader UK is a UK digital automotive marketplace that offers a vehicle buying and selling process. To provide you with the full range of Free Trader UK products and services, we need to collect and process certain information about you.
This Notice and our Cookies Policy apply to all visitors to and users of:
- the Free Trader UK website at www.gloucestersaab.co.uk (the "Website");
- any Free Trader UK website that links to this Notice and/or our Cookies Policy;
- Free Trader UK social media accounts;
- our mobile devices and Applications ("Apps").
It also applies to anyone contacting us by phone, SMS, email, in letters and other correspondence, in person and via social media.
If you are a dealer contracted with us, please see the privacy notice that is available via the Portal for information regarding the personal information we hold and use in order to provide your dealership with requested products and services.
For the purposes of this Notice, the data controller is Free Trader UK Limited (registered in England and Wales under company registration number 03909628) and whose registered office address is at Free Trader UK Limited, 4th Floor, 1 Tony Wilson Place, Manchester, M15 4FN.
References in this Policy to "Free Trader UK" also apply to its sister channels on this Website, including: Commercial Trader, Free Trader UK Bikes, Free Trader UK Trucks, Free Trader UK Plant, Free Trader UK Vans, Free Trader UK Farm, Free Trader UK Motorhomes, Free Trader UK Caravans and Prestige Cars "Top Marques".
If you have any questions regarding the use of your personal data please contact us at: [email protected]
Data Protection , Free Trader UK Limited, 4th Floor, 1 Tony Wilson Place, Manchester, M15 4FN.
Information collected by us and how we use it
To create an account, we will collect your email address and your chosen password. Once you have registered you can include further personal details in your account including your name and you can view your adverts, payment history and subscriptions with us. Where you log in via Facebook or another social media account, we may be provided with limited personal details (including your account ID and email address) to verify you are logged in. We will use your name and email address to send you communications about your account.
- Legitimate Interest
We use your name and email address to register your account and send you service communications about how to access and manage your account (available within the "My Free Trader UK" section of the Website). You can access the "My Free Trader UK" area at any time to update your details and can also change your options regarding marketing communications from Free Trader UK and/or third parties that you have selected in this area.
As part of the advert placement process on the Website, we collect your name, telephone number, email address and postcode, as well as details of the vehicle you wish to sell (including the vehicle registration number VRM) and device ID and IP address.
- Legitimate interest
- Legal Obligation
Click here for an explanation regarding the legal basis.
We use your name and email address to register your account and place your advert, confirm that your advert has been published and send you service communications about how to access and manage your account (available within the "My Free Trader UK" section of the Website) and your advert. You can access the "My Free Trader UK" area at any time to update your details and can also change your options regarding marketing communications from Free Trader UK and/or third parties that you have selected in this area.
We use your postcode to provide a positioning of the vehicle you advertise within our database; this allows potential buyers to locate vehicles for sale within a set radius of their chosen location. Your postcode is not disclosed in your advert.
Vehicle Registration Numbers (VRM) are required to place an advert on the Website for regulatory and security purposes. We will not disclose the Vehicle Registration Number within the text of your advert to any person. However, if the Vehicle Registration Number is displayed in photographs within your advert then these details will be visible to Website visitors who may use them without your authorisation.
If your advert expires we will contact you via phone or email to give you the option to rebook your advert.
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.
We use certain features in our advert placement process to protect the privacy of our customers when they are communicating with potential buyers via phone or email.
For customers placing a Private advert, we apply a Protect Your Number facility as a default on all adverts when customers provide 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 of using this facility, your telephone number will be visible within your advert.
For customers placing Private adverts, we also provide a customer to customer email service that allows Website visitors and potential buyers who view your advert to contact you via a link displayed on your advert, without disclosing your email address. We use this to disable any potential harmful links that may expose you to fraudulent activity. The use of the customer to customer email service is mandatory for us to maintain security of our Website. 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 card details to place your advert. We use third party payment providers to manage online card payment transactions. Payment card information is collected over a secure online payment gateway provided by:
All payment transactions processed are encrypted. Your payment card information is used solely to process payment for your advert. We retain no record of your payment card details.
When you communicate with us, you may provide personal data to us such as your name, address, contact details, organisation details, dietary requirements. We will use this in order to deal with your communication.
- Legitimate interest
You may provide your personal data to us for one of the following reasons:
- To request information about advertising with Free Trader UK or about any of Free Trader UK's services;
- To make a complaint;
- To enquire about working with us whether the enquiry is made by you personally or on behalf of an organisation;
- To register for and/or attend an event; and/or
- To respond to a survey.
When using services on Free Trader UK you will need to provide certain personal information such as name, email address, telephone number and postcode and details regarding your vehicle (including vehicle registration number, mileage, make and model) to enable us or a third party to provide you with the services requested. Depending on the service, this information may be passed to a third party.
Valuation – You will need to provide details regarding your vehicle in order to obtain a valuation. This may be the vehicle registration number and mileage and/or other details regarding your vehicle such as the make and model.
Vehicle Search facility - You will need to supply your postcode in order to use our vehicle search facility. We will use this to present adverts matching your search criteria with the distance from your selected location.
Request for test drive/quote/brochure - If you book a test drive of a new vehicle, or request a quote or brochure, through the Website you will need to provide your name, email address, postal address and telephone number which will be passed to the relevant dealer or other third party. Each request form clearly indicates that you are giving authorisation for your details to be passed to the relevant dealer or other party for them to contact you and action your request.
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 Live Person Automotive, the Dealer with whom you communicate, and will be made available to Free Trader UK. Additionally, the Chat Service provider may use computer infrastructure which is situated outside of the EEA. By using the Chat Service, you acknowledge and agree that any personal data disclosed by you while using the Chat Service will be processed and stored by the Chat Service provider on its systems outside the EEA and protected by adequate safeguards.
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.
- Legitimate interest
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.
To administer, maintain, develop and improve our Website and services, we use your contact details and details of your activity on the Website and interactions with us such as name, telephone number, email address and postcode, details of adverts you have published, details within the My Free Trader UK section of the Website and your interactions with us.
- Legitimate Interests
We will use your contact details such as name, telephone number, email address and postcode, details of adverts you have published, details with the My Free Trader UK section of the Website and details of your activity on the Website and your interactions with us in order to:
- 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 (including where customers have supplied their insurance renewal date information and/or vehicle ownership details).
- support our 'Send to Mobile' functionality. This allows visitors to our Website to send details of vehicles for sale to their mobile phone.
- identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.
The Legal Basis we rely on for processing your information
Under data protection laws, we are required to have a legal basis to process your personal information. We have set out below the legal bases we rely on:
- Contract: To perform a contract entered into with you and fulfil our contractual obligations to you or to take steps at your request prior to entering into a contract. This processing is necessary for us to provide the service you have requested including registering and managing your account publishing your advert and providing service updates and our support services.
- Consent: To provide information and take actions in relation to services which you have opted-in to receive. This includes where you specifically request for your details to be passed onto a third party (e.g where you make an enquiry regarding a test drive or a vehicle for sale) or where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers). For further information regarding consent please see below.
- Legal Obligation: Where processing is necessary to comply with our legal or statutory obligations. This may include cooperating with police in relation to their investigations.
- Legitimate interest: Where necessary for our legitimate interests or those of a third party. We rely on this basis in order to monitor and improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, to personalise content provided to you, to deal with enquiries and complaints, undertake market research and inform our general marketing, to run our business and maintain the security or our Website and services for you, us and other Website visitors and customers.
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 Free Trader UK to process your personal data you may withdraw consent at any time by emailing [email protected] 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.
Free Trader UK will not pass on your personal data to third parties except as set out in this Notice 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:
- 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 or consented to receive details of via the Website or the Apps. In certain circumstances, vehicle manufacturers (including Ford Motor Company Limited) or bike manufacturers and other relevant third parties may subsequently transfer, process and store your personal information outside of the European Economic Area ("EEA") for their business and administration purposes. in accordance with their own privacy policies. 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.
- 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. 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.
- As a security measure we use 2 factor verification when you login to your account We send your mobile number and a code to a third party provider (IOVOX or Clickatel) who will send you a code to enable you to login.
- Where we are under a duty to disclose or share your personal information with a third party 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 Free Trader UK 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/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or 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 prevent fraud or any adverse effect to those third parties consumer rights.
We are not responsible for any use of your personal data by these parties except where they act as our processor.
Free Trader UK will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy. All information you provide to us is stored securely within the EU, and not transferred outside the EEA unless specifically detailed in this Policy.
Payment card information, details you provide when requesting dealer or other third party services through the Website and information you provide when using the Chat Service is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the EEA in accordance with their privacy policies.
Where we transfer your data outside of the EEA, we will ensure that safeguards are in place to provide similar degree of protection is available to protect it. This may include contractual protections in place with our service providers or transferring your data to countries or parties which are recognised as providing suitable protection by the European Commission.
Certain parties to whom we disclose your personal data may transfer your data outside of the EEA after we disclose it to them as part of their business and administration activities (see above, Disclosure of your information). We are not responsible for any use of your personal data by these parties except where they act as our processor. If you have queries or require more information on how these third parties use your information, including such transfers outside of the EEA, please read their privacy policies or contact them.
Free Trader UK uses strict procedures and security features designed to prevent any unauthorised access to your data that we hold.
Free Trader UK will process personal data for as long as necessary to fulfil the purpose we collected it for, including the purpose of legal, accounting and reporting requirements, and for as long as necessary for the prevention and detection of criminal activity.
The period for which we process and store the personal data for varies depending on the use you make of the Website and the products and/or services we offer. Where you register an account or place an advert we will retain your data for as long as your account and/or advert is live and a period after your account is closed or advert ends to enable us to satisfy our legal, accounting and reporting 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.
Under data protection law, you have the following rights:
- Erasure/Right to be forgotten
- Restrict processing
- Object to processing
Some of these rights may not always apply. You can read more about your rights below.
You may be able to exercise the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you. In the event that Free Trader UK 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 or erasure/ to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restrict 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 supervisory authority – you have the right to complain as outlined in Section 8 below.
If you wish to make a complaint about how your personal data is being processed by Free Trader UK (or third parties as described above), or how your complaint has been handled, in the first instance please email your concerns to [email protected]
You also have the right to lodge a complaint directly with the UK supervisory authority which is the Information Commissioner’s Office and can be contacted via the details at www.ico.org.uk.