1. Introduction to this Policy
1.2 You should read this Policy carefully as it contains important information about how we will use your Information (as defined below in clause 4.1). In certain circumstances (see below) you will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit such Information to or through the Websites. For further information about consent see clause 7 below.
1.3 The Websites are not intended for children and we do not knowingly collect data relating to anyone under the age of 18.
1.4 We may update this Policy from time to time in accordance with clause 18 below. This Policy was last updated on 3rd April 2020.
2. About us
2.1 The terms “Automotive World” or “us” or “we” refer to Automotive World Limited, the owner of the Websites. We are a company registered in England and Wales under company number 04242884 whose registered office is at 1 – 3 The Washington Building, Stanwell Road, Penarth, South Glamorgan, CF64 2AD. The term “you” refers to the individual accessing and/or submitting Information to the Websites.
2.2 We, as the Data Controller, can be contacted via our representative, Michael Franklin, Chief Technology Officer, via email or call +44 (0) 2920 707 021.
3. Data Protection
3.1 References in this Policy to:
3.1.1 “Privacy and Data Protection Requirements” means: the Data Protection Act 2018 (“DPA”), the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Electronic Communications Data Protection Directive (2002/58/EC) (as updated by Directive 2009/136/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioners Office or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and
3.1.2 “Personal Data”, “Data Controller” and “Data Processor” and “processing” shall have the meanings given to them in the GDPR.
3.2 For the purposes of applicable Privacy and Data Protection Requirements, we (Automotive World) are a Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Privacy and Data Protection Requirements. “Personal Data” has a legal definition but, in brief, it refers to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Such information must be protected in accordance with applicable Privacy and Data Protection Requirements.
4. Information we may collect about you
4.1 When you use the Websites and/or when you otherwise deal with us we may collect the following information about you (“Information”):
4.1.1 Personal Information including first and last name and username or similar identifier;
4.1.2 Contact Information including current business address, primary email address and/or primary phone number;
4.1.3 Financial Information including bank account and payment card details and details about payments to and from you and other details of services purchased by you from us;
4.1.4 Technical Information including IP address, operating system, browser type and related information regarding the device you used to visit the Websites, the length of your visit and your interactions with the Websites;
4.1.5 Usage Information obtained through our correspondence and monitoring in accordance with clause 5.2 below including but not limited to your interests, preferences and feedback you provide;
4.1.6 Details of any enquiries made by you through the Websites, together with details relating to subsequent correspondence (if applicable); and
4.1.7 Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
5. How is your Information collected?
5.1 We use different methods to collect data from and about you including through direct interactions with you. You may give us your Information by filling in forms on the Websites or corresponding with us by post, phone, email or otherwise. This includes Information you provide when you:
5.1.1 create an account on our Websites;
5.1.2 subscribe to our services provided through the Websites or subscribe to certain publications and newsletters we provide;
5.1.3 apply to receive our services;
5.1.4 request marketing to be sent to you;
5.1.5 give us feedback or contact us.
5.3 Occasionally we may receive information about you from other sources, or from any third-party websites and applications that integrate or communicate with the Websites in relation to you. If so, we may add this information to the Information we already hold about you in order to help us carry out the activities listed below. This may include receiving Technical Information from analytics providers such as Google who may be based outside of the European Union.
6. How long we keep your Information
6.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax and accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
6.2 Subject to clause 6.3, we will keep your Information only for the purposes set out in the table below for:
6.2.1 Ten years where the legal basis for the processing that it is necessary for the performance of the contract between us; or
6.2.2 until consent is withdrawn, where the legal basis is express consent.
6.3 If required, we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
6.4 In some circumstances you can ask us to delete your Personal Data see ‘your rights’ below for further information.
7. Legal basis for processing your information
7.1 We may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is set out in the table below.
7.2 We have also identified what our legitimate interests are where appropriate. We may process your Information for more than one lawful ground depending on the specific purpose for which we are using your Information. Please contact us if you need details about the specific legal basis we are relying on to process your Information where more than one basis has been set out in the table below.
|Why we will process your Information||The legal basis for which is…|
To register your membership details as a user of the Websites, whether under a single-user licence, team site license or enterprise site licence, which will allow you use to access the content on our Websites, including articles, research, data, conferences and webinars.
To investigate and address any comments, queries, for example, about our membership prices, or to answer any questions or complaints about the Website or any webinars or conferences attended by you, and any similar or related comments, queries or complaints from other customers.
Necessary for the performance of the contract with you
Necessary for the performance of the contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our website users updated)
To send you the newsletters, emagazines, that you have subscribed for as part of your membership with us and to ensure that content from the Websites and in our webinars is presented in the most effective manner for you and for your device.
To allow you to participate in interactive features of the Website, including inputting information and providing feedback.
To understand and measure the effectiveness of the content from our Websites and webinars we present to you.
Necessary for the performance of the contract with you
Necessary for our legitimate interests (to study how users of the Websites use our services, content and webinars, to develop them, to grow our business and to inform the content we display and inform our marketing strategy).
To arrange billing, and administration of membership licences you purchase from us and collect and recover money owed to us.
Necessary for the performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To research into usage and behaviour for improving and changing our services, including personalisation to your needs.
Necessary for our legitimate interests (to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy)
To operate, administer, maintain, provide, analyse and improve the Websites and the services available to you through the Websites.
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
To contact you for marketing purposes (see ‘Marketing and opting out’ in clause 9 below);
We send out marketing communications based on our legitimate interests of providing a professional services business and keeping people informed about the services we offer. The method of communication may vary as set out below:
we may send you information via post or, if you are dealing with us on behalf of a limited company or LLP, to your corporate email address;
we will only contact you via your personal email address if:
you have given your consent (see ‘Marketing and opting out’ in clause 9 below); or
you have previously bought services from us and we are contacting you to let you know about similar services that we offer.
You have the right at any time to let us know that you no longer wish to receive marketing communications from us (see ‘Marketing and opting out’ in clause 9 below).
To disclose your information to selected third parties as permitted by this Policy
Necessary for our legitimate interests (for the running of our business and to keep the Websites updated and relevant) and the legitimate interests of third party knowledge partners or sponsors who post content on the Websites (to ensure the content posted on the Websites is targeted and relevant).
Where your Information is shared with third parties for marketing purposes, this processing will be subject to your consent (see clause 8 and 9 below)
You have the right at any time to let us know that you no longer wish us to disclose your information to third parties for marketing purposes.
Where required by (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity.
This is necessary to comply with our legal obligations, including obligations relating to the protection of Personal Data.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
8. Your consent to processing
8.1 As noted above, you will be required to give consent to certain processing activities before we can process your Information as set out in this Policy. Where applicable, we will seek this consent from you when you first submit Information to or through the Websites.
8.2 If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account on the Websites or by notifying us in writing (see clause 21 below).
8.3 If you withdraw your consent, and if we do not have another legal basis for processing your information (see clause 7 above), then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights (for which see clause 15 below).
8.4 Please note that if we need to process your Information in order to operate the Websites and/or provide our services, and you object or do not consent to us processing your Information, the Websites and/or those services may not be available to you.
9. Marketing and opting out
9.1 Where you are dealing with us on behalf of a limited company or LLP, for business purposes, then we may contact you by email to your corporate email address about similar or related products that we offer. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see clause 9.4 below).
9.2 Where you have previously purchased services from us, or have requested information from us, you may receive marketing communications from us in relation to similar or related services, promotions and special offers that may be of interest to you. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see clause 9.4 below).
9.3 We will get your express consent before we share your Personal Data with any third party for marketing purposes. If you have opted-in, we may share your Personal Data with carefully selected third party organisations, including knowledge and business partners who provide content for the Websites and they may contact you directly (unless you have asked them not to do so) by mail, telephone and email about products, services, promotions and special offers they offer that may be of interest to you. If you prefer not to receive direct marketing communications from such third parties, or you no longer wish to receive them, you can opt out at any time (see clause 9.4 below).
9.4 Opting out. You have the right at any time to ask us, or any third party, to stop processing your Information for direct marketing purposes. If you wish to exercise this right, you should email us, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively, you can follow the unsubscribe instructions in emails you receive from us or them.
10. Disclosure of your information
10.1 We may disclose your Information (including Personal Data):
10.1.1to other companies within our group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);
10.1.2 to our business, knowledge partners and sponsors, service providers or third-party contractors to enable them to undertake services for us and/or on our behalf (and we will ensure they have appropriate measures in place to protect your Information);
10.1.3 to any prospective buyer or seller (and their representatives) in the event that we sell or buy any business or assets;
10.1.4 if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, including (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity; and
10.1.5 to other third parties if you have specifically consented to us doing so.
10.2 We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers, to assist us in the improvement and optimisation of the Websites. In such circumstances we do not disclose any information which can identify you personally.
10.3 If our business or assets are sold, transferred or integrated with another business, your Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business who may use your Information in the same way as set out in this Policy.
10.4 If you are using the Automotive World Website: If you register for one of our webinars on the Automotive World Website, we may share your Personal Data (including your name and email address, together with the details of the webinar(s) attended), with our sponsors. The sponsor may store your Information in its address databases, may share that information within its group, and may contact you to keep in touch provided you have expressly opted-in to receiving such communication. Our sponsors rely on legitimate business interests to ensure the content they post is targeted and relevant and to uphold meaningful business relationships with entities and individuals who are interested in learning more about their knowledge, products and services which is made available through Automotive World Website. Legal basis is Article 6 (1) (f) GDPR.
10.5 If you are using Mobex: Once you have signed up to use Mobex you will be able to access all keynote presentations made available by us through Mobex on behalf of our knowledge partners. We may share your Personal Data (including your name and email address, together with details of the keynote presentations viewed by you) with our knowledge partners. The knowledge partner may store your Information in its address databases, may share that information within its group, and may contact you to keep in touch provided you have expressly opted-in to receiving such communication. Our knowledge partners rely on legitimate business interests to ensure the content they post is targeted and relevant and uphold meaningful business relationships with entities and individuals who are interested in learning more about their knowledge, products and services made available through Mobex.
11. Keeping your Information secure
11.1 We will use technical and organisational measures in accordance with good industry practice to safeguard your Information, including the use of data encryption.
11.2 While we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed in clause 7 above.
13. Overseas transfers
13.1 From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (“EEA”). Non-EEA countries that we may need to transfer your Information to include:United States, Canada, India, Japan, Australia, China, South Korea and Brazil because our knowledge partners are based there.
13.2 Such countries may not have similar protections in place regarding protection and use of your Personal Data as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with applicable Privacy and Data Protection Requirements to ensure adequate protections are in place to ensure the security of your Information. Please contact us if you want further information on the specific mechanism used by use when transferring your Personal Data out of the EEA.
13.3 By submitting your Information to us in accordance with this Policy you consent to these transfers for the purposes specified in this Policy.
14. Information about other individuals
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Information; receive on his/her/their behalf any data protection notices; and give consent to the transfer of his/her/their Information abroad (if applicable).
15. Your rights
15.1 If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details in clause 21 below) giving us enough information to identify you and respond to your request. These rights include:
15.1.1 the right to request access to information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing;
15.1.2 the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information deal with the change or correction;
15.1.3 the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case, we will let you know;
15.1.4 the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see clause 15.6 below);
15.1.5 the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you, we will let you know;
15.1.6 the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know;
15.1.7 the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we will let you know;
15.1.8 the right to object to direct marketing, for which see clause 9.4 above.
15.2 No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
15.3 What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
15.4 Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any concerns about how we collect or process your Information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
17. ‘Cookies’ and related software
17.1 Our software may issue ‘cookies’ (small text files) to your device when you access and use the Websites and you will be asked to consent to this at the time (e.g. when you first visit our websites). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
17.3 You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of our Websites features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.
18. Changes to this Policy and duty to inform us of changes
18.1 We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on this page, and place notices on other pages of the Websites as applicable, so that you may be aware of the Information we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version this Policy as it will apply each time you access the Websites.
18.2 This Policy was last updated on 3rd April 2020.
18.3 It is important the Information we hold about you is accurate and current. Please keep us informed if your Information changes during your relationship with us.
19. Links to other websites
19.1 Our Websites may contain links to other websites, plug-ins and applications. This Policy only applies to our Websites. If you access links to other websites any Information you provide to them will be subject to the privacy policies of those other websites.
19.2 We have no control over third party websites or systems and accept no legal responsibility for any content, material or information contained in them. Your use of third party sites or systems will be governed by the terms and conditions of that third party. It is your responsibility to ensure you are happy with such third-party terms and conditions.
19.3 The display of any hyperlink and/or reference to any third-party website, system, product or service does not mean that we endorse that third party’s website, products or services and any reliance you place on such hyperlink, reference or advert is done at your own risk.
This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
21. Contact us
We welcome your feedback and questions on this Policy. If you wish to contact us, please contact our Data Protection Officer via email or by calling +44 (0) 2920 707 021.