PRIVACY NOTICE

Euro Car Parts Limited is a company registered in England and Wales (hereinafter referred to as "we", “our” or “us”).

OVERVIEW

Maintaining the security of your data is of paramount importance to us and we are committed to respecting your privacy rights.

This notice, which including without limitation applies when using Ebay (“our marketplace listing”), provides you with information about:

• How we use your data
• What personal data we collect
• Who we share your data with
• How we ensure your privacy is maintained; and
• Your rights relating to your personal data

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (EU Regulation 2016/679, when applicable, the “GDPR”), and the EU Data Protection Directive (Directive 95/46/EC), the data controller is Euro Car Parts Limited of T2 Birch Coppice Business Park, Danny Morson Way, Dordon, Tamworth, England, B78 1SE.

INFORMATION WE MAY COLLECT FROM YOU AND OTHER SOURCES

Although the precise details of the personal information collected will vary according to the specific purpose for which we are collecting the information, we may collect and process the following data about you:

• Information that you provide when purchasing goods through our eBay marketplace listings or when contacting us through eBay.
• If you contact us through eBay Messages and is provided voluntarily, we may keep a record of that correspondence.
• The sole purpose of any recording is for training and quality control purposes. Under the GDPR any personal or confidential information disclosed shall not be made available to any third party (unless required by law to do so) or used for marketing purposes. Recorded conversations are deleted within three months after the recording was made.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our eBay marketplace listings.
• We obtain certain personal information about you from sources outside our business which may include our group of companies (further defined below). We may receive your personal information from other sources, such as: public databases, our retail and supplier partners, referrals from insurance and accident management companies, joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, this other personal data helps us to:
• Provide the relevant services in an accurate manner;
• review and improve the accuracy of the data we hold; and
• improve and measure the effectiveness of our marketing communications, including online advertising.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• To provide the products and services you request through your eBay purchase.
• To carry out our obligations relating to your eBay order, including sharing delivery information with our delivery partners where necessary.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
• Whether you are a new or existing customer, if you have consented to being contacted electronically we will contact you in accordance with your consents.
• We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any personal harm to you. It is in your vital interests for us to use your personal information in this way.

DISCLOSURE OF YOUR INFORMATION

In order to make certain services available to you, we may need to share your personal data with third parties.

• We may disclose your personal information to:
• any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
• our trusted service providers that assist with order processing, delivery, and customer support where necessary;
• our courier company who delivers your orders (such as DHL);
• selected third parties if you are a new customer and you have consented to this;
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Euro Car Parts Limited substantially sell all of its assets or are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Euro Car Parts Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

International Transfers

It is sometimes necessary for us to share your data outside of the European Economic Area (EEA). This generally occurs when our service providers are located outside of the EEA or you are based outside of the EEA.

If this happens, we will ensure that the transfer will be compliant with the relevant data protections laws including the GDPR.

Where personal data is transferred internationally, we will ensure appropriate safeguards are in place in accordance with applicable data protection laws.

HOW DO WE PROTECT YOUR DATA

We are committed to keeping your personal data safe and secure and employ a number of security measures such as:

• We use appropriate technical and organisational measures to help protect personal data;
• Monitoring and auditing our service providers to ensure they have an adequate level of protection as required under the PCI DSS;
• All information you provide to us is stored on our secure servers. We ask you not to share a password with anyone.

We use reasonable, organisational, technical and administrative measures to protect personal information under our control. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

The personal data that you provide to us in order to purchase goods and other personal data generated for transactional agreements is processed as it is necessary for the performance of a contract with you.

All other personal data is processed for our legitimate interests (as set out below) and to comply with our legal obligations.

In general, we only rely on opt-in consent as a legal basis to contact (and allow for selected third parties to contact) new customers by electronic means and/or send direct marketing communications via еmаil or text message to new customers.

You have the right to withdraw your consent at any time.

Our legitimate interests

The normal legal basis for processing customer data, is that it is necessary for our legitimate interests including:-

• selling and supplying goods and services to our customers;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers;
• understanding our customers’ behaviour, activities, preferences, and needs;
• complying with our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries, complaints or disputes;
• managing insurance claims by customers;
• protecting us and our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
• effectively handling any legal claims or regulatory enforcement actions taken against us; and
• fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

YOUR RIGHTS

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – 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.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below in the "Contact" section.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

You can also exercise the right at any time by contacting us at Euro Car Parts Limited by any of the means outlined below.

HOW LONG DO WE KEEP YOUR DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Our procedures to manage data retention is to retain customer data for 7 years to support some of our parts warranty.

Data back-ups can take up to 60 days to remove specific data from the system.

We will take reasonable steps under Article 17 of the GDPR to meet data subject requests.

CHANGES TO OUR PRIVACY NOTICE

Any changes to this privacy notice will be reflected in our current eBay listing where applicable.

CONTACT

If you have any questions about how we use your personal data, please contact us through eBay Messages.

You also have the right to make a complaint to your applicable data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Issue Date: 14 June 2018