Privacy Policy

Introduction

Effective date: April 2022

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our service, including the MOTOM mobile application, and the choices you have associated with that data.

We use your data to provide and improve our service. By using our service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our End User Licence Agreement which can be accessed via the following link: https://Motom.io/end-user-license-agreement/.

Motom Limited trading as MOTOM and Motom for business and Motom for personal (MOTOM) is committed to treating your personal information in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (together “the Act”) and the Principles of Data Processing (“the Principles”) as set out in the Act.

To comply with our obligations under the Principles, MOTOM has a privacy policy which sets out how we manage privacy in our organisation. Our privacy policy is set out in this document. Further information may be obtained by writing to MOTOM (see below for contact details).

MOTOM will review this policy from time to time to update and continually improve our processes. If this policy is amended at any time, the updated version will be posted on our websites at www.motom.io or available to you upon request.

Purpose of the policy

MOTOM takes its obligations under the Act seriously. We have privacy obligations to our users and customers who utilise the services provided by MOTOM.

Personal Information

Personal data is defined in the Act as any information relating to an identified or identifiable natural person (known as a ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to any information that would identify them. This might be a name, address, identification number or information that is held online. Some of the data may be sensitive in nature and need a higher level of protection. Sensitive information is a type of personal information that includes health, genetic or biometric information, or information or an opinion which indicates racial or ethnic origin, religious beliefs or affiliations, membership of a trade union, profession, trade association or political association, political or philosophical opinions, sexual orientation or practice, or criminal record.

For the purpose of this policy, personal data may include, but is not limited to the following:

• Name, address, email and contact details;
• Information, including:
• Your name and the name of the business you represent, the key contact names and positions of persons within the business, and the email address, postal address, location, website address and telephone number of the business and natural persons attached to it.
• We also collect and process business information which we use in our Customer Relationship Management (CRM) system, the information collected for CRM purposes includes:
• A profile of the business, including the types of cars sold, brands and services provided by the business, the trading names of the business, the type of business;
• For segmentation and profiling purposes for MOTOM CRM, the estimated unit sales, the OEM/s you represent, market segments you operate in, number of cars or other automobiles you re-market/dispose of each year;
• Information in identification documents (e.g., Company Registration Number, VAT Number, FCA Number);
• Bank account details;
• Financial information and financial status; (Business Search / Credit File)
• Transaction history, for example the number, brand and type of cars sold;
• Your image on film or photograph if you attend one of our events;
• Feedback and responses to surveys and/or promotions;
• Changes to content or preferences; and
• Information provided on our website or during communication with us.

Collection holding and using personal information

MOTOM may collect personal data for the purposes of fulfilling a contract or where it has a legitimate interest, for example, for the operation of our service and the operation of the MOTOM Application or for marketing purposes by us or third parties if we have your consent.

When practicable, personal data will only be collected from the individual concerned. There are a number of methods of collecting personal data directly from the individual, including (but not limited to):

• When you visit our websites, including (but not necessarily limited to the following:
  • https://www.motom.io; and
  • https://www.motom.io/dashboard or https://app-prod.Motom.io/dashboard (referred to as the “MOTOM Control Centre”);
• When you interact with our team members, including via telephone (mobile or fixed line), the chat function on our websites or e-mail;
• In person or in writing;
• Submitting feedback on business and the industry at our request or voluntarily; and in the course of supplying our services to you.

We may also collect personal information about you by indirect means including from our clients, contractors, suppliers and other associates, and from publicly available sources. If MOTOM collects your personal information by indirect means, we will take reasonable steps to inform you that we have collected your personal information.

The type of information that MOTOM collects about you will depend on the nature of the service provided.

We collect, hold and use your personal information for the primary purpose for which it is collected. We may also use your personal information for related purposes that you would reasonably expect including:

• To identify you;
• To create and manage your user file within the MOTOM CRM, MOTOM Application and the MOTOM Control Centre;
• To provide information on the MOTOM Application and MOTOM Control Centre “my connections” and “other users” (enabling users and customers to network)
• For segmentation and profiling purposes for MOTOM database to provide and improve our services;
• To provide our services & support to you;
• To improve our services and business;
• Promotional purposes and sending marketing materials to you;
• To address your complaints;
• In relation to your image on film or photograph taken at an event, to report the event, to promote such an event in future, to promote us and may be used in the publicly available website(http://motom.io) or in digital/print media relevant to promotional activities.
• To comply with our legal obligations and other purposes authorised by the Act; and
• For promotional and marketing purposes provided by third parties.

If you do not provide us with your personal information, we may not be able to provide you with all of our services. It may also affect your use of the MOTOM website. (However, if you do not want your personal information to be used in this way, you may opt-out by contacting us at any time. You may opt out of any marketing services by contacting us at any time.)

If you provide us with personal information about another person, you must only do so with their consent and you warrant that the other person is aware of this Privacy Policy and any applicable Privacy Statement.

Disclosure of personal information

We may disclose your personal information to our employees, officers, related bodies corporate and third parties as far as reasonably necessary for the purposes set out above. The third parties to whom we may disclose your personal information include:

• Third party service providers to whom we outsource some of our functions;
• Insurers, assessors, and underwriters;
• Professional advisors and consultants (such as lawyers, accountants, and auditors);
• Government and regulatory authorities, as required by law and/or in the course of providing our services to you; and
• Website hosts & website developers.

We may also disclose your personal information third parties (including for marketing purposes) where authorised by you, where permitted/required to do so by law or where you have consented.

Disclosure to third parties

Where we disclose personal information to third parties we will take reasonable steps to ensure that they comply with the Act, including the Principles. We will only transfer personal information to countries outside of the United Kingdom where they have personal data legislation that is at least equivalent to the Act and the Principles or we have a legal agreement in place which provides the equivalent protection.

If MOTOM is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

MOTOM may disclose your personal data in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of MOTOM
• To prevent or investigate possible wrongdoing in connection with our services
• To protect the personal safety of users of our services
• To protect against legal liability 

Data security

MOTOM stores information in different ways, including in hard copy or electronic format. MOTOM will take all necessary technical measures to protect personal data from loss, misuse or unauthorised access. Some of the steps that MOTOM has taken to protect the security of your personal data include:

• Computer and network security including passwords and other electronic barriers;
• Policies for destroying or permanently de-identifying personal information no longer required (subject to legal requirements for retaining certain records);
• Restricting access to those MOTOM employees and contractors who need it to perform legitimate MOTOM business activities and responsibilities;
• Confidentiality undertakings from our employees, contractors and other service providers.

Payments

We may provide paid products and/or services within the services we provide, including the MOTOM Application. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors by you whose use of your personal data is governed by their privacy policies. It is your obligation to check that you are satisfied with their privacy policies and the way they process your personal data.

The payment processors we work with are:

• Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Google Play In-App Payments
Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
• Stripe
Their Privacy Policy can be viewed at https://stripe.com/privacy-shield-policy

Website, Cookies and Web Analytics

MOTOM websites at https://www.motom.io, https://www.motom.io/dashboard (MOTOM websites) are hosted in the UK.

When you visit MOTOM websites we may collect certain information such as server address, browser type, operating system, website visited immediately before coming to our site, the pages you accessed on the websites, how long you visited, the date and time you visited, your geographical location and type of device used. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our services.

We may also use ‘cookies’. A cookie is a small file MOTOM websites place on your computer so that they can remember your preferences and improves your experience of MOTOM websites. You can block placement of cookies in your browser settings. You can also clear cookies from your browser. If you do this, some parts of MOTOM websites might not work as well.

MOTOM websites use Google Analytics and Firebase which collects information about the use of the website and traffic to the website. We use Google Analytics to promote our goods and services, including by allowing us to provide advertising to you on websites not owned by us. You can choose to opt-out of Google Analytics and Firebase collecting and using your data by downloading the Google Analytics & Firebase Opt-out Browser Add- on.

The MOTOM privacy policy extends to any personal information collected from MOTOM websites.

MOTOM websites contain links to other internet sites belonging to other parties and are not subject to MOTOM’s privacy policy. MOTOM does not guarantee the completeness, accuracy of, or accept any responsibility for, information contained within any linked sites. You will need to contact those websites to determine their privacy policy.

Quality and correction

MOTOM will endeavour to ensure that the personal information we hold about you is complete, accurate and up to date. In order to assist us to achieve this, it is important that you advise MOTOM when your details change, are inaccurate or not up to date such as when you change address. You may contact MOTOM at any time if you would like your details corrected.

MOTOM members can assist by ensuring that all their details are correct on membership renewal forms.

Access

MOTOM will provide access to the personal data that we hold about you except in limited circumstances (for example, when providing access would have an unreasonable impact on the privacy of others or denying access is required or authorised by law).

Requests for access to your personal data should be in writing to [email protected]. We will respond to all requests for access within 30 days. In the interest of protecting the privacy of all of our users and customers, MOTOM must properly identify you (for example, by requiring some form of identification such as a driver’s licence or passport) before access to information is provided.

If your request is accepted, access may involve you inspecting or taking notes or making photocopies of your personal data. If your request is rejected, we will provide reasons for denying access.

Generally, there is no fee for access to personal information. However, MOTOM may charge a reasonable fee for access if the information is archived or if MOTOM has incurred administrative costs in locating and/or reproducing the information. This will never exceed £10.00.

You may contact MOTOM on the contact details provided below at any time to request information about generally the sort of personal information MOTOM holds, for what purposes and how it is collected, used and disclosed.

Complaint handling process

If you have any concerns about the way your personal information has been managed by MOTOM you may make a complaint to us. We request that you put your complaint in writing mailed to the address or email set out below. We will investigate and respond to privacy complaints within 30 days.

If you are not satisfied with the response we provide, you may contact the Information Commissioner’s Office with your query or complaint. Contact details for the Information Commissioner’s Office are set out below.

Opt out

You may withdraw your consent to MOTOM or third parties using your personal information for marketing purposes at any time by giving MOTOM notice.

Contact MOTOM

If you have queries, concerns, or would like to access or revise your personal records maintained by MOTOM, please contact MOTOM:

Contact us:
Attn: Company Secretary
Business Name: MOTOM Limited
Address: 153 Milton Keynes Business Centre Foxhunter Drive, Linford Wood, Milton Keynes, Buckinghamshire, England, MK14 6GD
Email: [email protected]
Website: www.motom.io

More information

More information about the Act and the Principles is available from the Information Commissioner’s Office at www.ico.org.uk.