Privacy Policy

INTRODUCTION

This Privacy Policy describes your rights as a visitor or customer of Supercar Group Ltd (“We”, “Our” or “The Company”). It provides information about your rights relating to your personal information along with how we collect, use and share your data.

We are committed to protecting your data and abiding by all laws, including the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

By visiting the website at www.supercargroup.co.uk (“Site”) you (the “User”) are accepting and consenting to the practices described in this policy.

We encourage our Users to carefully read this Privacy Policy and use it to make informed decisions.

GROUNDS FOR DATA COLLECTION

Processing of your Personal Information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information “) is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

WHAT INFORMATION DO WE COLLECT?

We collect two types of data and information from Users.

The first type of information is non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device:

• Certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site.
• We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Communication information: When you contact us via our Site you may be asked to provide certain details such as: your name, phone number, e-mail or physical address, and other information as necessary.

HOW DO WE RECEIVE INFORMATION ABOUT YOU?

We receive your Personal Information from various sources:

• When you voluntarily provide us your personal details by filling in a contact form or registering on our Site
• When you use or access our Site (see Cookies)
• From third party providers, services and public registers (for example, traffic analytics vendors).

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

HOW DO WE USE YOUR INFORMATION?

Provided that we have obtained your consent to the extent we are required to under the data protection legislation, we may use the information we receive and/or collect about you to:

• Fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested;
• Send you newsletters and marketing information if you have consented to us doing so;
• Notify you of products and services we offer that are similar to those you have purchased or enquired about; and
• Notify you of changes to our services and products.

We collect and process much of your personal information on the grounds of Legitimate Interests, which includes some or all of the following:

• Where the processing enables us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of our customers;
• To identify and prevent fraud;
• To enhance the security of our network and information systems;
• to better understand how people interact with our websites;
• Administer the website and carry out data analysis, troubleshooting and testing;
• To determine the effectiveness of promotional campaigns and advertising; and
• To monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website.

If we require your personal data for fulfilment of a contract with you, we may be unable to fulfil the contract without your personal data.

You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, please let us know by emailing us at info@supercargroup.co.uk. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, subsidiaries, affiliated companies and subcontractors, who may be located in different jurisdictions across the world, for any of the following purposes:

• Hosting and operating our Site;
• Providing you with our services;
• Storing and processing such information on our behalf;
• Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget to any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services;
• Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to:

• comply with any applicable law, regulation, legal process or governmental request;
• (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof;
• (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
• (iv) to establish or exercise our rights to defend against legal claims;
• (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
• (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

HOW DO WE SAFEGUARD YOUR INFORMATION?

Your personal information is kept secure at all times and we use the latest technology to ensure that all our data is kept confidential, especially personal information that we hold.

Your information may be kept in a number of places, all of which comply with data protection requirements. We use cloud providers and online application providers to help us run our business and information we manage may be transferred and store to destinations outside of the UK and Europe. All reasonable steps are taken to ensure that your personal information is managed and secured appropriately, at all times. Confidentiality agreements, contracts and sharing agreements are all documents we use to ensure that partners, suppliers and third parties are all managing your personal data responsibly, transparently, fairly and within the law.

All transfers of personal information regardless of destination will comply with the law, at all times.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We will not share your personal data unless there is a valid legal reason or need to do so.

HOW LONG WE HOLD PERSONAL INFORMATION

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

USER RIGHTS

You may request to:

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your personal information that is in our control.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict processing of your personal information by us.
• Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:

info@supercargroup.co.uk

COOKIES

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

The Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the Website. It also allows us to improve the Website.

A “cookie” is a small piece of information that a website assigns to your device while you are viewing it. Cookies are very helpful and can be used for various purposes. These purposes include:

• Allowing you to navigate between pages efficiently
• Basic functioning of the Website
• Enable automatic activation of certain features
• Remembering your preferences and making the interaction between you and our Services quicker and easier.

Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Site uses the following types of cookies:

• Strictly necessary cookies. These are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.
• Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

THIRD PARTY COLLECTION OF INFORMATION

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

TRANSFER OF DATA OUTSIDE THE EEA

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

ADVERTISEMENTS

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

CORPORATE TRANSACTION

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

MINORS

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@supercargroup.co.uk

UPDATES OR AMENDMENTS TO THIS PRIVACY POLICY

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

HOW TO CONTACT US

If you have any general questions about the Site or the Information we collect about you and how we use it, you can contact us at info@supercargroup.co.uk

www.supercargroup.co.uk

If you have any complaints about our use of your personal data, please contact us. You are also entitled to report any concerns which you may have to supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office. You can call the ICO on 0303 123 1113 or get in touch via other means as set out on the ICO website at https://ico.org.uk/concerns/.

If you have any further queries or comments on our policy, please contact us by emailing info@supercargroup.co.uk. We always welcome your views about our Website and our Privacy and Cookie Policy.

Last Modified: 29/01/2024