• the Caribads website at www.caribads.app (the “Website”);
• any Caribads website that links to this Notice and/or our Cookies Policy;
• Caribads social media accounts;
• our mobile devices and Applications (“Apps”).
• In this Notice, references to the Website include the Apps, where applicable.

For the purposes of this Notice, the data controller is Caribads that gives top priority and values the privacy and security of the information that you share with us through Caribads.app. We want our buyers and sellers to feel fully comfortable using Caribads.app. It is important for you to understand how we collect, use, and maintain your information.
When you want to buy any item from Caribads.com you need to register our site then you can purchase an item. Upon registration, we collect your information about you.

To create an account, we will collect your email address and your chosen password and (if you choose to provide it) 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 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 “caribads“ 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 Caribads“ area at any time to update your details and can also also change your options regarding marketing communications from Auto Trader and/or third parties that you have selected in this area.

Where you make (or start) an online order on the Website, we may contact you regarding your online order, as described in the ‘Online Orders‘ section below.

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 device ID and IP address.

Legal basis:

• Contract
• Legitimate Interest
• Legal Obligation

More Information

We use your name and email address to register your account and your 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 Caribads“ section of the Website) and your advert. You can access the “My Caribads“ 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.

We use your location to provide a positioning of the Item you advertise within our database; this allows potential buyers to locate Items for sale within a set radius of their chosen location. Your postcode is not disclosed in your advert.

For ads, Vehicle Registration Numbers (VRM) are required to place an advert on the Website for regulatory and security purposes. We will not disclose the Vehicle Registration Number within the text of your advert to any person. However, if the Vehicle Registration Number is displayed in photographs within your advert then these details will be visible to Website visitors who may use them without your authorisation.

If your advert expires we will contact you via phone or email to give you the option to rebook your advert.

We may also use the information you provide for internal business records and purposes, including to analyse and develop our products and services and the Website.

We use certain features in our advert placement process to protect the privacy of our customers when they are communicating with potential buyers via phone or email.

For customers placing a Private advert, we apply a Protect Your Number facility as a default on all adverts when customers provide their phone number. Protect Your Number enables you to keep your telephone number private by providing you with a substitute telephone number to use in your advert. You will need to contact our Customer Service team if you wish to remove this facility. Please be aware that if you opt out of using this facility, your telephone number will be visible within your advert.

For customers placing Private adverts, we also provide a customer to customer email service that allows Website visitors and potential buyers who view your advert to contact you via a link displayed on your advert, without disclosing your email address. We use this to disable any potential harmful links that may expose you to fraudulent activity. The use of the customer to customer email service is mandatory for us to maintain security of our Website. We reserve the right to monitor and retain all communications via the email service for security monitoring purposes.

You will also be required to supply payment card details to place your advert. We use third party payment providers to manage online card payment payment transactions. Payment card information is collected over a secure online payment gateway provided by:

• Stripe – processed in accordance with their privacy policy: https://stripe.com/gb/privacy

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.

• Consent
• Legitimate interest
• Contract

• To request information about advertising with Auto
• Trader or about any of Auto Trader’s services;
• To make a complaint;
• To provide feedback to us on your experience of using the Website and our services;
• 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;
• To enter a competition or prize draw, including via social media; and/or
• To respond to a survey.

• Legitimate Interest
• Consent

To administer, maintain, develop and improve our Website and services, we use your contact details and details of your activity on the Website, use of our Services and interactions with us such as name, telephone number, email address and postcode, details of adverts you have published, details within the My Caribads section of the Website, your interactions with us and, where applicable, details relating to your finance application and the decision of the lender or broker (as applicable).

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 Caribads 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.
• create a profile of you, which enables us to identify and personalise what you see on our Website and Apps and what vehicles and services we offer to you for marketing purposes (as further described in the section below).
• 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.
• where you use the Finance Application Services (as detailed above), we will anonymise details relating to your finance application and the decision of the lender or broker (as applicable), combine it with other anonymised data that we have collected and use machine learning to build a profile of customers who are likely or unlikely to be accepted for a certain finance product.

Profiling and automated decision making

We may profile your activity on our Website and Apps to help us:

• better understand the types of vehicles and services you may be interested in;
• customise your experience on our Website and Apps, for example, by suggesting vehicles and/or services that may be of interest to you;
• where you use the Finance Application Service (as described above) (where possible and where the relevant lender or broker doesn’t offer the same functionality), to provide you with an eligibility score at the “soft check” stage (which is the percentage likelihood of you being accepted for a certain finance product) based on the information that you have provided and the information that we receive from Experian and/or Equifax;
• tailor our communications with you; and
• to identity opportunities to improve our products and services and those of the Auto Trader Group.

We do not make automated decisions which will have a legal or similar effect on you.

You can always object to profiling by emailing us at dataprotection@caribads.app

Any profiling data that we hold about you will only be kept for as long as is necessary to meet the above objectives.

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; administering and processing your online order; 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 carry out profiling and 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 Caribads to process your personal data you may withdraw consent at any time by emailing dataprotection@caribads.app. 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.

Caribads 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 dataprotection@caribads.app if you have any queries regarding your rights. You can exercise your rights as set out above by emailing dataprotection@caribads.app. 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 dataprotection@caribads.app.

You also have the right to lodge a complaint directly with the your country supervisory authority which is the Information Commissioner’s Office.