Privacy policy

This Privacy Policy was last updated on 16 July 2019. Motorway Online Ltd (“Motorway”, “we” or “us”) offers on its website (the Website) a service notifying dealers of vehicles for sale and allowing vehicles to bid for and potentially buy such vehicles (the Service).

In order to provide these Services, we require certain information from the dealer. This policy sets 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 take up our Services or use the Website, we will collect certain information about you, such as:

  • basic contact information you provide to us;
  • records of how you use our Services;
  • information we obtain from public sources;
  • 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 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

For a dealer requesting Services, 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 generally manage the sales process.

Records of how you use our Services

This may include details of your use of our website, and records of any purchase you make.

Information we obtain from public sources

If we wish to confirm your identity, we obtain information about you 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, search information providers or social networks) and may receive information about you from them to make sure our Services are as effective 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 if you enter a competition or prize draw on our Website 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;
  • 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 our Services, including:

  • to facilitate your use of our Services in accordance with the applicable terms of use, which includes sharing your information with vehicle 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 and other third parties in order to provide you with our Services;
  • to send you offers, promotions or other marketing 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 is 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 dealers information as set out in the applicable terms of use in particular:

  • in order to provide a seller with bids from dealers who may be interested in purchasing the vehicle and generally manage the sale process.
  • to connect sellers and dealers in order to enable the dealer to inspect and purchase the vehicle and generally manage the sales process.
Method of collection

This information will be provided by you directly when you first take up our Service 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 Services 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.
  • 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 establish and protect our business and legal rights or to defend ourselves against any legal actions.
  • 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.

Legal basis

It is our legitimate business interest to manage and administer our Services 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 in accordance with your specified preferences (if applicable).
Method of collection

Your contact details will be collected when you request a valuation from us and your account is created 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. You can also manage your information and update your marketing preferences by sending an email to privacy@motorway.co.uk. Please allow up to two business days for any opt out request to be processed. We may continue to send you relevant service messages about your account and our services if you have unsubscribed from emails or SMS.

To improve and develop our Services and Website
  • we conduct data analytics and benchmarking in order to understand, for example, the best performing Car Buying Partners and the most relevant Car Buying Partner for given vehicles and customer types. This enables us to improve our Services and offer the best and most relevant offers to our customers.
  • 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.
  • we conduct data analytics on the 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; and
  • service providers, such as data storage providers, content and data providers and customer management and support providers;

Find out more…

Seller of a Vehicle

When you 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 car, we will receive certain information about your transaction from the relevant Seller of a vehicle, such as the date of the car sale and the final 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:

  • 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 purposes.
  • 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: Such providers deliver personalised email or SMS reminders to you in relation to your cars available for sale, and collect reviews of our Services.

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.

We may also share your personal information with third parties in other circumstances:

  • 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 required in order to obtain professional advice concerning a complaint, claim or potential claim relating to you; and
  • 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.

Storage of your personal information

Information about you 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, such as a European Commission adequacy decision, the EU-US Privacy Shield Certification or the EU Model Contracts, 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 it (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

You 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;
  • data portability, in certain circumstances;
  • opt out from our using it for direct marketing; and
  • lodge a complaint with the Information Commissioner’s Office in the UK which is responsible for upholding your data protection rights.

You are able to exercise these rights by contacting us at 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 process 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.

Each European Union country has a supervisory authority responsible for upholding data protection rights. In the UK, this is the Information Commissioner’s Office.

You also have the right to obtain a remedy from 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 3369 1747.