Surron Bikes UK Privacy Notice (“Notice”) (last updated 26th June 2023)

Surron Bikes Uk is a UK digital automotive marketplace that offers a vehicle buying and selling process. To provide you with the full range of Auto Trader 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 Surron Bikes Uk website at https://surronbikesuk.com (the “Website”);
  • any Surron Bikes Uk website that links to this Notice and/or our Cookies Policy;
  • Surron Bikes Uk social media accounts;
  • our mobile devices and Applications (“Apps”).

In this Notice, references to the Website include the Apps, where applicable.

It also applies to anyone contacting us by phone, SMS, email, in letters and other correspondence, in person and via social media

“Data Protection legislation” means all applicable data protection and privacy legislation in force from time to time in the UK including the UK GDPR; the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426)

“UK GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data as it forms part of the lawof England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act of 2018

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.https://

For the purposes of this Notice, the data controller is Auto Trader Limited (registered in England and Wales under company registration number 03909628) and whose registered office address is at Auto Trader Limited, 4th Floor, 1 Tony Wilson Place, Manchester, M15 4FN.

References in this Policy to “Auto Trader” also apply to its sister channels on this Website, including: Commercial Trader, Auto Trader Bikes, Auto Trader Trucks, Auto Trader Plant, Auto Trader Vans, Auto Trader Farm, Auto Trader Motorhomes, Auto Trader Caravans and Prestige Cars “Top Marques”.

If you have any questions regarding the use of your personal data please contact us at: sales@surronbikesuk.com

or

Data Protection,
Auto Trader Limited,
4th Floor,
1 Tony Wilson Place,
Manchester,
M15 4FN.

  • To create an account, we will collect your email address and your chosen password and (if you choose to provide it) your full name and telephone number. Once you have registered you can update your personal details in your account at any time and you can view your adverts, payment history and subscriptions with us. If you later provide your full name and telephone number, at the time of creating an online order on the Website, this personal information will be saved in your account. 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.

    Legal basis:

    • Contract
    • Legitimate Interest

    More Information

    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 Auto Trader“ section of the Website). Where you have provided a telephone number, we may also use this to contact you about your account. You can access the “My Auto Trader“ area at any time to update your details and can also change your options regarding marketing communications from Auto Trader and/or third parties that you have selected in this area.

    If you log-in via Facebook or another social media account, those sites may automatically give us access to your limited personal details (including your account ID and email address) in order to verify if you are logged in with their site. Once you are logged-in to our Website your data will be handled by us in accordance with this Privacy Policy and the Cookie Policy. We are not responsible for any use of your personal data by Facebook or any other social media site and you should review their privacy policies.

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.

Legal basis:

  • Contract
  • Legitimate Interest
  • Legal Obligation

Click here for an explanation regarding the legal basis.

More Information

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 Auto Trader“ section of the Website) and your advert. You can access the “My Auto Trader“ area at any time to update your details and can also change your options regarding marketing communications from Auto Trader and/or third partiesthat 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. Pleasebe 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.

Where you are given the option to try and sell your car at auction and you take up this offer, we will pass your details onto our partner, Dealer Auction, who will process your personal data in accordance with their privacy notice. We will save your advert details and use your email address to keep in contact with you during the auction process, including to contact you, if the auction is unsuccessful, in order to help you continue to list your car on our Website.

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.

Legal basis:

  • Consent
  • Legitimate interest
  • Contract

More Information

You may provide your personal data to us for one of the following reasons:

  • To request information about advertising with Auto Trader or about any of Auto Trader’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 Auto Trader 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.

Legal basis:

  • Contract
  • Consent
  • Legitimate Interest

More Information

Valuation – 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.

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 yourname, email address, postal address and telephone numberwhich 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.

Chat Service – If you use the chat service, available on some dealer adverts, to communicate with dealers (“Chat Service”), you may disclose your name, email address and other personal information to adealer while using the service. The Chat service is provided by a third party provider. Please refer to the relevant Chat Service provider’s privacy policy for further information about how they process your personal data.

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 relevant Chat Service provider, the dealer with whom you communicate, and will be made available to Auto Trader. 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.

Online Orders – If you place an online order and reservation of a vehicle on the Website, you will need to provide your name, email address and (at your option) telephone number. We will use this information to send you an email confirmation of your order and keep you updated as your order progresses. If you don’t complete your order, we will save the details you have already entered in your account and use your email address to remind you to complete your order.

We will also pass your information to the relevant dealer at the time you submit your order, so that they can contact you regarding your order

AutoTrader’s support team (Auto Trader OrderExperts) may also contact you by email and/or (where you provide your telephone number) SMS and/or telephone to discuss the progress of your order and to gain feedback on your experience of making an online order on the Website, in order for us to try to improve our services.

Where you request a Valuation (in connection with a part exchange transaction) and/or use our Finance Application Service as part of your online order, please refer to the relevant sections relating to those services.

You will be required to supply payment card details in order to complete your order and reserve your vehicle. 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 vehicle reservation. We retain no record of your payment card details.

Finance Application Service – If you use this service at autotrader.co.uk please note the following:

Assessing Suitability for Finance and Completing a Soft Search

In order for us to assess your suitability for finance and to provide you with a personalised quote, we initially use your personal data to complete a soft search which involves checking the information you provide against the credit reference agencies referred to below and against lender criteria held by Auto Traderand/or its service providers. The information you provide may include the following information about you (and any joint applicants):

  • personal details (for example, name, date of birth and marital status);
  • contact details (for example, address, email address and phone number);
  • employment details (for example, employment status, job title, income and employer’s contact details);
  • information to verify your identity (for example, address history and whether you have a valid driving licence and UK passport); and
  • details of the vehicle you wish to buy (including the vehicle registration number).

As a result of an automated process, which uses credit history from the credit reference agencies and filters this information against lender lending criteria, you will be presented with the details of lenders who you may be able to obtain a loan from. Please note that this does not guarantee that you will be able to obtain a loan from these lenders.

This will not have any adverse effect on your credit rating and the softsearch on your credit file will only be visible to you. However, you are only able to proceed to a full inance application on our Website or App with one of the lenders for whom our processes deem that you might be eligible. This may also mean that you are unable to proceed to a full finance application on our Website or App where there are no lenders whose criteria are met using the soft check process.

To complete a soft search we share your personal data with Equifax and Experian and you should ensure you are happy with their privacy notices:

  • Equifax: https://www.equifax.co.uk/ein.html
  • Experian: https://www.experian.co.uk/privacy/consumer-information-portal
  • In the case of the lender(s) listed below, who offer additional capability we will share information about you (and any joint applicants) with the applicable lender(s) at this “soft search” stage in order for the lender(s) (acting as a data controller in their own right) to make an assessment (which may include automated processing or profiling) based on their complete lending criteria in order to provide you with: (i) an enhanced personalised quote; and/or (ii) an eligibility score, which is the percentage likelihood of you being accepted for certain finance product. There is no impact on your credit score as only a soft search will be carried out by the credit agencies (as described above). You should ensure that you are happy with the relevant Lender’s privacy notice.
    Santander: https://www.santanderconsumer.co.uk/your-data/privacy-policy/

Full Finance Application

Where you proceed to a full finance application, you will need to provide some further information as requested by the relevant lender. We will share information about you and any joint applicants with the lender, and the relevant dealer who is selling the vehicle, so that they can progress your application. Note that Auto Trader acts a data controller in respect of its processing of your personal data for the purposes of providing and administrating the finance application service and the lender and the dealer each act as a data controller in their own right in respect of their processing of your personal data for the purpose of progressing your application and the sale of the vehicle (as applicable). You should ensure you are happywith the lender’s and the dealer’s privacy notice, which is available from the lender and dealer (as applicable) on request.

Your application for finance is determined by the lender.

Additional Information

If you are making a joint finance application, wewill create a joint record for you and the other person(s) and so you must ensure you have their consent prior to disclosing their personal data. You must also bring this Notice to their attention

We will use the information you provide, and that we obtain from the credit agencies and lenders, in order to present the results of any finance application via the Website or App.

If you do not complete the form which enables us to complete a soft search and present quotations to you, we will send you a reminder email enabling you to complete the process

We will process your data which we collect in respect of Finance Application Service in accordance with the “How long do we keep your data’ section of this Notice below.

Your rights

Under data protection law, you are entitled to the following rights where decisions are made using automated means:

  • the right to obtain human intervention
  • the right to express your point of view in relation to the decision
  • the right to contest a decision

This is in addition to the rights listed in the ‘Your rights as a data subject’ section below.

Please email dataprotection@autotrader.co.uk if you have any queries regarding your rights. You can exercise your rights as set out above by emailing dataprotection@autotrader.co.uk. This request may be shared with a third party (such as Equifax or Experian, who may carry out the soft credit check on our behalf) in order to fully respond to you.

Leasing

If you apply to lease a vehicle, you will need to provide the following information about you:

  • personal details (for example, name, date of birth, marital status, number of dependents, gender and nationality);
  • contact details (for example, address, email address and phone number);
  • employment details (for example, employment status, job title, income and employer’s contact details);
  • employment details (for example, employment status, job title, income and employer’s contact details);
  • information to verify your identity (for example, address history and whether you have a valid driving licence and UK passport);
  • your income and expenditure details (for example, details of your personal and household income, your personal monthly expenses, whether you have any existing vehicle finance and, if so, the vehicle registration; and
  • your bank details.

We will share your personal information with our group company, Autorama UK Ltd (trading as ‘Vanarama’) (“Vanarama”), who we have partnered with to provide the leasing services. Vanarama acts as a data controller in its own right in respect of their processing of your personal data for the purpose of progressing your leasing application and (if your application is successful) the administration of your leasing agreement. When you submit your application, Vanarama will share your personal data with the lender and the lender will contact credit references agencies to perform a credit check. This may be a hard credit check, which will be visible to other lenders on your credit report. For further information about how Vanarama processes your personal data, please see Vanarama’s privacy notice at https://www.vanarama.com/legal/privacy-policy.

The lender also act as a data controller in respect of its processing of your personal data and you should ensure you are happy with the lender’s privacy notice, which is available from the lender on request.

Once Auto Trader has passed your application to Vanarama, it will only retain your name and contact details. Auto Trader’s support team may use this information to contact you by email and/or (where you provide your telephone number) SMS and/or telephone to discuss the progress of your leasing application and to gain feedback on your experience of making a leasing application on the Website, in order for us to try to improve our services. If you are eligible for a cashback offer (which we may offer on certain leasing deals from time to time), and you choose to claim the cashback, Vanarama may share your bank details (for the same account set up for the monthly payments of the vehicle lease) with us so that we can process your cashback payment.

  • 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.

    Legal basis:

    • Legitimate Interest
    • Consent

    More Information

    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 Auto Trader section of the Website and your interactions with us.

    Legal basis:

    • Legitimate Interest
    • Consent

    More Information

    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 Auto Trader 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.
    • provide a user-friendly online search experience. This includes the use of website analytics tools as described further in our Cookie Policy.
    • identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.

We may receive personal data about you from various third parties, including (without limitation) the following:

  • Companies that enable us to collect your reviews and comments, both online and offline;
  • Companies that collect your reviews and comments on behalf of dealers.

Legal basis:

  • Consent
  • Legitimate Interest

Click here for an explanation regarding the legal basis.

More Information

We offer the ability for individuals to leave reviews of dealers on the Website. Some of our dealers use Feefo Holdings Limited (“Feefo”) to collect reviews (on the Website and also by direct emails to consumers) and the data Feefo receives is processed in accordance with their privacy policy: www.feefo.com/en/business/privacy-policy. Feefo shares the reviews with us (including any personal data disclosed by the reviewer as part of the review), which we publish on our Website. Feefo will also share the reviewer’s name, age and location, where the reviewer has consented to this information being shared with us. If the reviewer does not give their consent, Feefo will only share the reviewer’s first name and surname initial, which will appear with the review on the Website.

Some dealers use different third party providers to collect reviews on their behalf and they share such reviews with us. Please refer to the relevant review provider’s privacy policy for information about how they process your personal data.

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 or a dealer 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 Auto Trader to process your personal data you may withdraw consent at any time by emailing dataprotection@autotrader.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 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.

Surron Bikes 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 our partners, dealers, vehicle manufacturers, bike manufacturers, finance providers, auction houses and other 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 thirdparty 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.
  • The Chat service is provided by a third party, LivePerson Automotive and data they receive is processed in accordance with their privacy policy.
  • Some dealers ask us to share their Feefo reviews and any connected personal data relating to the reviewer with Reputation.com (who provide a review management platform and related services), to enable the dealer (and, in somecases, a vehicle manufacturer acting on the dealer’s behalf) to manage and reply to dealer’s reviews via Reputation.com’s platform. Please speak to the dealer for further details and to review their privacy notice.
  • 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 Auto Trader 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.

Surron Bikes 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.

More Information

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:

  • Access
  • Rectification
  • Erasure/Right to be forgotten
  • Restrict processing
  • Portability
  • Object to processing
  • Complain

Some of these rights may not always apply. You can read more about your rights below.

More Information

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 Auto Trader 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.

Please email sales@surronbikesuk.com if you have any queries regarding your rights. You can exercise your rights as set out above by emailing sales@surronbikesuk.com . All of the above requests will be forwarded on should there be a third party involved (as set out in this Privacy Policy) in the processing of your personal data.

If you wish to make a complaint about how your personal data is being processed by Auto Trader (or third parties as described above), or how your complaint has been handled, in the first instance please email your concerns to sales@surronbikesuk.com

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.