Privacy Policy

1. Who we are

Dealer2Trade Auctions, a trading name of Redding and Redding Limited, is a UK wholesale (Trade registered only) digital automotive marketplace.

To provide you with Dealer2Trade Auction products and services, we need to collect and process information about you.

You can contact us at:

Dealer2Trade Auction
Buckingham Ford
Ford Street
Buckingham
MK18 1AQ

If you wish to contact our Data Controller you can do so by emailing support@dealer2trade.co.uk

2. Our Privacy Promise

Dealer2Trade Auction is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it. It's important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.

This Privacy Policy explains:

• What information Dealer2Trade Auction collects about you;
• How Dealer2Trade Auction collects and uses information about you;
• Whether Dealer2Trade Auction discloses your details to anyone else;
• The choices available to you regarding the personal information you provide to us; and
• When and how your data may be shared with third parties.

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

We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended and the General Data Protection Regulations (GDPR).

3. Your consent

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 Dealer2Trade Auction to process your personal data you may withdraw consent at any time by emailing support@dealer2trade.co.uk. 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 in the process of buying or selling a vehicle 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.

4. What we collect and why

We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:

• Contract: To enter into a contract with you and fulfil our contractual obligations to you (e.g. to publish your auction listing). This processing is necessary for us to provide the service you have requested including registering and managing your account 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.

We use the information we collect to:

• enable the performance of the contract you are entering into when using our service;
• 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;
• provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email;

Dealer2Trade Auction collects the following information when you set up an account:

(a) Personal data including your name, address, email address, telephone number and mobile telephone number as well as data on your company and trading style to confirm your trade status and eligibility to use the platform

This data is collected to register your account and place your listings as well as to send you service communications about your account. We may share certain personal data, such as contact details, with dealers or individuals interested in purchasing your vehicles as part of our standard trading

Once you have registered and your account is approved you can edit your personal details in your account. Once you are logged-in to our Website in your use of the Website and your data will be handled in accordance with this Privacy Policy and the Cookie Policy.

(b) We also collect additional personal data which may be generated as a result of the use of your account such as invoices and other records related to payments and transactions.

Dealer2Trade Auction collects the following information when you use our products & services:

(d) As part of the listing placement process on the Website, we collect your postcode, as well as details of the vehicle you wish to sell, and your IP address. This information is used as follows:

1. Postcode: to provide a positioning of the vehicle you list. This allows potential buyers to locate vehicles listed within a set radius of their chosen location
2. Vehicle Registration Numbers: are required to place a listing on the Website for regulatory and security purposes. The vehicle registration number as I am sure you will understand is a major part of any listing you make and will be prominent in any listing you make. if the Vehicle Registration Number is displayed in photographs within your listing then these details may be visible to Website visitors who may use them without your authorisation.
3. We may also use the information you provide for internal business records and purposes, including to analyse and develop the Website and apps associated

If you choose to 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 manufacturer of your device.

All payment transactions processed for buying or selling of vehicles is arranged between the Authorised user and the buyer/purchaser, whom also will be an authorised user of this platform, please note we operate a service platform and will not facilitate the payment process between a buyer or a seller.

5. Disclosure

Dealer2Trade Auction will not pass on your personal data to third parties except as set out in this policy 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:

• Information may be shared with people employed by Dealer2Trade Auction and Redding and Redding Limited where necessary for us to provide you with the products and services that you have signed up to receive.
• We use Dealer2Trade Auction to handle sign up, Redding and Redding Limited to handle invoicing and payments for certain services provided by Dealer2Trade Auction and so we will share certain personal data with them in order for them to do this. In this context Redding and Redding Limited operate as a data processor acting on behalf of Dealer2Trade Auction
• 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 (e.g. Facebook). 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.
• Where 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.
• If we sell or buy any business or assets, in which case Dealer2Trade Auction may disclose your personal data to the prospective seller or buyer of such business or assets.
• We may share your personal information with Redding and Redding Limited
• 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 list 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.

6. Your rights in relation to your personal information

You have the following rights in relation to the personal information Dealer2Trade Auction processes relating to you. Where you exercise these rights, Dealer2Trade Auction 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, Dealer2Trade Auction will explain our reasons why.

Taking into account the complexity and number of requests, it may take Dealer2Trade up to 90 calendar days to respond to your request. Where Dealer2Trade intend to extend the deadline for responding, you will be informed within 30 calendar days of receipt of your request

6.1 Right of Access

You have the right to request access to the personal information that Dealer2Trade hold about you.

6.2 Rights in relation to inaccurate personal information

Where personal information that Dealer2Trade Auction 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.

6.3 Right to erasure

In certain limited circumstances, you have the right to request that Dealer2Trade Auction erase personal information relating to you that Dealer2Trade Auction holds. This right only applies if any one of the following circumstances applies:

• Where Dealer2Trade Auction 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 are 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 has been unlawfully processed.
• Where Dealer2Trade Auction 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 Dealer2Trade Auction 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.

6.4 Right to restriction of processing

You have the right to request that Dealer2Trade Auction 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 Dealer2Trade Auction 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 Dealer2Trade Auction no longer needs the personal information for the purposes set out 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 above. 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 Dealer2Trade Auction 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 Dealer2Trade Auction 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.

6.5 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 Dealer2Trade Auction
• Where the grounds for processing the personal information stated 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 out 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 Dealer2Trade to another controller.

6.6 Right to object to processing

You have the following rights in relation to objecting to the processing of your personal information by Dealer2Trade Auction:

6.6.1 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

6.6.2 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 Dealer2Trade Auction will no longer process it for that purpose.

6.7 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 Dealer2Trade Auction
• Is authorised by or under any law to which Dealer2Trade Auction is subject, or
• Is based on your explicit consent.

6.8 Right to complain to the Information Commissioner's office

Where you believe that Dealer2Trade Auction has failed to properly comply with its obligations in respect of your personal information, including your rights as set out above, you can complain to the Information Commissioner.

The Information Commissioner's Office's address is:

The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can find more information about their role and how to submit a complaint on their website: www.ico.org.uk.