Dealer Privacy Policy

    This Privacy Policy was last updated in October 2023. Motorway Online Ltd is the owner and operator of a used car marketplace.

    Save for where specified otherwise, capitalised terms on this page shall bear the same meanings as those given to them in our Motorway Pro Terms.

    In order to provide you with access to the Motorway Platform and the Transport Services, we require certain information from you. This policy details the types of personal information we collect and process about you, what we use it for, and how we will treat it. Please read this policy carefully and contact us if you have any questions as set out below.

    Information we process about you

    When you use the Motorway Platform, we will collect certain information about you, such as:

    • basic contact information you provide to us;
    • transaction and payment information;
    • delivery details (e.g., where you elect to use Motorway Transport);
    • records of how you access and use the Motorway Platform;
    • information we obtain from public sources (e.g., for the purposes of carrying out anti-money laundering and know-your-client checks);
    • information we receive from third parties (e.g., business partners, service providers, advertising networks, analytics providers, automotive data providers, search information providers or social networks);
    • records of communications you have with us;
    • other information you and your staff provide to us voluntarily, including as part of a survey or promotion; and
    • technical information about your device and website usage, including cookies (see our Cookies Policy).

    Find out more…

    Basic contact information you provide to us

    When you sign up to use the Motorway Platform, we will collect your name, post code, email address, telephone number and the company you work for. Amongst other things, we will use this information to contact you in respect of any Bids you make and, otherwise, to generally manage the sales process.

    Transaction and payments information

    When you sign up to use the Motorway Platform, and again whenever you purchase a Vehicle, we (or our third party payments provider) will collect bank and/or Modulr account details from you to enable us to both send and receive payments to or from you for our services. We will also keep a record of any purchases you make through the Motorway Platform.

    Delivery details

    If you elect to use Motorway Transport in order to have a Vehicle collected and dropped off, we will use your contact details and delivery preferences to facilitate this with our delivery partners.

    Records of how you use the Motorway Platform

    This may include details of your use of our Website, and records of any Vehicle purchases you make.

    Information we obtain from public sources

    As part of our onboarding process, and sometimes as part of audits or checks, we may obtain information about you and your business from third parties, such as Companies House.

    Information we obtain from third parties

    We may also work with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, automotive data providers, reference agencies, search information providers or social networks) and may receive information about you from them to make sure that the Motorway Platform is as effective and secure as possible.

    Records of communications you have with us

    If you contact us with a question or query or to provide us with feedback, for instance, we will keep a record of your communications with us.

    Other information you provide to us voluntarily, including as part of a survey or promotion

    This may include data that you provide to us on our Website, to your account manager, or the details of any feedback that you provide to one of our online surveys or focus groups.

    Technical information about your device and website usage

    When you use our Website, we collect certain technical information including:

    • details about your device, such as your IP address, device type, operating system and browser; and
    • information relating to use of the Website, such as the pages you visit and elements of the page you interact with.

    How we use your personal information

    We use personal information about you for various purposes connected with your use of the Motorway Platform and our Transport Services, including:

    • to facilitate your use of the Motorway Platform in accordance with our Motorway Pro Terms, which includes sharing your information with Sellers if you have placed a Bid;
    • to communicate with you in relation to your use of our services and provide you with customer support;
    • for internal management, administrative and organisational reasons;
    • to share information with our suppliers, transport partners and their drivers, and other third parties in order to provide you with our services;
    • to send you offers, promotions or other marketing and/or information which we think you may find useful; and
    • to develop and improve our business, through the use of data analytics and benchmarking.

    In order to use your personal information, we must have a legal basis for doing so. The legal bases that we rely upon are explained further in the “find out more” section below. We will only use your personal information where it is necessary:

    • to fulfil our contract for services with you;
    • to comply with a legal obligation to which we are subject;
    • for our legitimate business interests that are not overridden by your interests, rights and freedoms.

    Where none of the above applies, we will request your consent (which we will ask for before we process the information).

    Find out more…

    The table below sets out further information about the purposes for which we use information about you, with the corresponding methods of collection and legal basis that we rely upon for its use.

    PurposeMethod of collection and legal basis for processing

    In order to provide you with the services you have requested, we need to collect and share your information in the following ways:

    • in order to provide Sellers with your Bids and generally manage the sale process;
    • to connect you with Sellers to enable you (or the transport provider) to inspect and purchase the Vehicle and generally manage the sales process;
    • where applicable, to provide our transport partners with your information in order to provide you with the Transport Services;
    		Method of collection

    This information will be provided by you directly when you first sign up for the Motorway Platform and set up an account with us and then during the course of using our services.

    Legal basis

    Necessary for the performance of the contract between you and us in relation to the services. In all other cases, it is our legitimate business interest to provide efficient price comparison services.

    To communicate with you
    • we will provide you with customer support and answers and/or respond to any queries or feedback that you send to us;
    • to assist you with any technical problems you have with the Motorway Platform or Website;
    • to collect reviews of our services in order to improve our business;
    • to update you with any changes to our terms and conditions/other policies.
    		Method of collection

    This information is collected any time when we communicate with you or you communicate with us.

    Legal basis

    It is our legitimate business interest to inform you of relevant information in relation to the services that we provide, respond to your communications and to improve our business.

    Internal management, administrative and organisational reasons

    • to manage our Website and the Motorway Platform;
    • to administer and manage our services and business in an efficient and proper way (e.g., accounting, billing, etc.);
    • to manage how we work with other companies that provide services to us;
    • to carry out know-your-client checks;
    • to establish and protect our business and legal rights or to defend ourselves against any legal actions;and
    • to comply with legal requirements and obligations to which we are subject.
    		Method of collection

    This information is collected from you both directly and indirectly, through Companies House and reference companies.

    Legal basis

    It is our legitimate business interest to manage and administer our services, the Motorway Platform, and Website, comply with laws to which we are subject and protect our business interests and legal rights.

    To share information with service providers
    • See the section Who do we share your information with, and for what purposes?for more detail.
    		Method of collection

    This may include any of the information we hold about you, whether collected by direct or indirect means.

    Legal basis

    It is our legitimate business interest to share your information with trusted third parties who provide us with services relevant to our provision of our services to you, including data storage providers, content and data providers and customer management and support providers.

    To send you offers, promotions or other marketing
    • To send you promotions, offers and bonuses that you may be interested in via email, text or post in accordance with your specific preferences (if applicable).
    		Method of collection

    Your contact details will be collected when you sign up for the Motorway Platform and may be updated (along with your preferences) from time to time.

    Legal basis

    It is our legitimate business interest to send you marketing and promotional materials from time to time.

    If we send you a marketing email, it will include details on how to unsubscribe from receiving similar marketing messages in the future.

    To improve and develop our services, the Motorway Platform, and Website
    • we conduct data analytics and benchmarking in order to understand, for example, the best performing Dealers and the most relevant Dealer for given Vehicles. This enables us to improve our services and offer the best and most relevant offers to our Dealers and Sellers alike;
    • we conduct data analytics and benchmarking to understand how our Website and services are used, for example, which pages are visited and which elements of the page are interacted with. This enables us to improve our Website and services; and
    • we conduct data analytics on the Seller Vehicle Data we collect, for example to understand the most popular makes, models or fuel types of vehicle and their values. This enables us to release information into the public realm about trends and changes in car ownership.
    		Method of collection

    This information is collected across your interactions with the Website and your use of our services.

    Legal basis

    It is our legitimate business interest to identify ways to develop and improve our services, Website and business.

    Who do we share your information with, and for what purposes?

    We may share your personal information with:

    • a Seller of a Vehicle if you have placed a Bid for that Vehicle;
    • service providers, such as our transport partners and their drivers, payments processing providers, data analytics and technical support providers, data storage providers, content and data providers and customer management and support providers (including our outsourced customer service centre);
    • law enforcement agencies or authorities where we believe this is necessary for the prevention, detection or enforcement of a crime; and
    • our professional advisers and investors.

    Find out more…

    Seller of a Vehicle

    When you place a Bid for a Vehicle, we share information about you (such as name, postcode, email address, telephone number and the company you work for) with the Seller of a Vehicle in order to facilitate a sale. If you proceed with the purchase of a Vehicle, we will receive certain information about your transaction from the relevant Seller of the Vehicle, such as the date of collection and the final Purchase Price you paid, for billing and reporting purposes.

    Our Service Providers

    We use carefully selected service providers which process personal information about you on our behalf as described below:

    • Transport partners: We use a network of trusted transport companies to provide you with Transport Services. They will receive the Seller Vehicle Data, along with details of the Seller, your delivery address, contact details, and preferred drop-off time.
    • Payments: Where you are set up to make payments through the Motorway Platform, you will be required to provide certain personal information to our third-party payments processing provider, Modulr FS Limited (“Modulr”). Modulr will be required to process your personal information in order for them to provide a payment account and provide services under the Payment Terms. Modulr is a Data Controller and shall only use your personal data for this purpose. Modulr’s privacy policy is available here.
    • Data analytics and technical support providers: Such providers assist us in better understanding your use of our Website, the Motorway Platform, and our Services.
    • Data storage providers: Such providers help operate the functionality of the Website and enable us to provide user accounts. They also provide backup, debugging and logging services.
    • Content and data providers: Such providers assist us to, for example, verify your email address and telephone number, use your town/city to calculate routes between you and the Seller of a Vehicle, and use your postcode to geocode your approximate location.
    • Customer management and support providers (including our outsourced customer service centre): Such providers deliver personalised email or SMS reminders to you in relation to your cars available for sale, and collect reviews of our services.

    Law Enforcement Agencies or Authorities

    We may have to share your personal information with law enforcement agencies or authorities where we are required to comply with certain legal and regulatory requirements, and may process your personal information for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject.

    This includes sharing your personal information where we believe this is necessary for the prevention, detection or enforcement of a crime (for example, if we believe that a transaction through our Website is fraudulent by using a stolen vehicle).

    Our Professional Advisers and Investors

    If required, we may share your personal information with professional advisers to obtain professional advice (for example, with a lawyer or insurer regarding a complaint, claim or potential claim relating to you).

    We may share your personal information if required as part of our obligations to our investors.

    We may also share your personal information with third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, along with its professional advisers.

    If you would like to receive a full list of our suppliers and other third parties who we share your information with then you can get in touch with us using the details provided in the section Contact Information.

    Storage of your personal information

    Information about you and your dealership may be transferred outside the UK to a country, territory or international organisation that may not have UK equivalent data protection standards.

    This may be when we transfer your personal information to our trusted third party service providers (for the purposes described above) outside of the European Union. In such cases, we will ensure that your personal information is protected by implementing appropriate safeguards. If you would like more information about any of the transfer safeguards on which we rely please contact us as set out in this privacy policy.

    How do we protect your personal information?

    We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy requirements.

    How long will your personal information be kept?

    The period for which we may retain information about you will depend on the purposes for which the information was collected, whether you have requested the deletion of the information, and whether any legal obligations require the retention of certain information (for example, for regulatory compliance). We will not retain information about you for longer than is necessary to fulfil the purposes for which it was collected.

    Your rights as an individual

    You as an individual* may have some or all of the following rights in respect of the information about you that we process:

    • request us to give you access to it;
    • request us to rectify it, update it, or erase it;
    • request us to restrict our using it, in certain circumstances;
    • object to our using it, in certain circumstances;
    • withdraw your consent to our using it (where we have initially relied on consent)
    • data portability, in certain circumstances;
    • the right to opt out from our using it for direct marketing; and
    • the right to lodge a complaint with the Information Commissioner’s Office, which is responsible for upholding your data protection rights in the UK.

    *Please note that these rights only relate to your personal information as an individual, and are not rights in respect of a company (i.e. your dealership).

    You are able to exercise these rights by contacting us, using the details set out in the section Contact Information.

    Find out more…

    You have the rights set out in the table below:

    Right in respect of the information we hold about youFurther detail (note: certain legal limits to all these rights apply)
    • To request us to give you access to it.
    		This is confirmation of:
    • whether or not we process your personal information;
    • our name and contact details;
    • the purpose of the processing;
    • the categories of information concerned;
    • the categories of persons with whom we share the information and, where any person is outside the EU, the appropriate safeguards for protecting the information; and
    • (if we have it) the source of the personal information, if we did not collect it from you;
    • the criteria for determining the period for which we will store the information.

      • On your request we will provide you with a copy of your personal information we hold.

    • To request us to rectify or update it.
    		This applies if the information we hold is inaccurate or incomplete.
    • To request us to erase it.
    		This applies if:
    • the personal information we hold is no longer necessary in relation to the purposes for which we use it;
    • we use the personal information on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all information about you in which case we will respect your wishes);
    • we use the personal information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
    • the personal information was unlawfully obtained or used; or
    • To comply with a legal obligation.
    • To request us to restrict our processing of it.
    		This right applies, temporarily while we look into your case, if you:
    • contest the accuracy of the personal information we use; or
    • have objected to our using the personal information on the basis of legitimate interest
      • (if you make use of your right in these cases, we will tell you before we use the personal information again).

    This right applies also if:

    • our use is unlawful and you oppose the erasure of the personal information; or
    • we no longer need the personal information, but you require it to establish a legal case.
    • To object to our processing it.
    		You have two rights here:
    • if we use your personal information for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and
    • if we use your personal information on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.
    • To withdraw your consent to our using it.

    This right applies to any personal information which we have collected and processed based on your consent.

    You have the right at any time to withdraw the consent you have provided to us.

    • To data portability.
    		This right applies:
    • To personal information that you have provided to us; and
    • if we use that personal information on the basis either of your consent, or on the basis of discharging our contractual obligations to you.

    If both (i) and (ii) apply, you have the right to receive the information back from us in a commonly used format, and the right to require us to transmit the personal information to someone else if it is technically feasible.

    • To lodge a complaint with the Information Commissioner’s Office or take your case to a national court.

    The UK’s supervisory authority responsible for upholding data protection rights is the Information Commissioner’s Office.

    You also have the right to obtain a remedy from a UK court.

    Contact information

    For the purpose of UK data protection law, the controller is Motorway Online Ltd (Company Number 10285711) of International House, 24 Holborn Viaduct, London EC1A 2BN.

    If you have any questions, or wish to exercise your rights, please contact us at any time on privacy@motorway.co.uk or 020 3988 2288.