AUDATEX CONSUMER VRM/VIN PRIVACY NOTICE

Introduction

AUDATEX respects your privacy and is committed to protecting your data. This privacy notice will inform you as to how we look after your VRM and VIN and tell you about your privacy rights and how the law protects you.

Important information and who we are
The VRM/VIN data we collect about you
How is your VRM/VIN data collected
How we use your VRM/VIN
Disclosures of your VRM/VIN
International transfers
Data security
Data retention
Your legal rights
Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how AUDATEX collects and processes your Vehicle Registration Mark (“VRM”) and Vehicle Identification Number (“VIN”).

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your VRM and VIN so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Audatex UK Limited, a company registered in England and Wales with registered number 02058567 and whose registered office is Capitol House, Bond Court, Leeds, LS1 5EZ, United Kingdom is the controller and responsible for your VRM and VIN (collectively referred to as ”AUDATEX”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Audatex UK Limited
Email address: GDPR[email protected]
Postal address: Capitol House, Bond Court, Leeds, LS1 5EZ, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice

This privacy notice may be updated by us from time to time. This version was last updated in July 2022. The most up-to-date version of the Privacy Notice can be found at https://www.audatex.co.uk/privacy

2. The VRM/VIN data we collect about you

We collect, use, store and process the following data about you:

Vehicle Data: Vehicle Registration Mark (VRM”), and Vehicle Identification Number (“VIN”).

3. How is your VRM/VIN data collected?

We collect your VRM/VIN data through:

Third parties
- Parties to the crash repair process such as accident management companies, credit hire companies, insurers and repairers who use our solutions and systems as part of the crash repair process
- OEMs

4. How we use your data

We will only use your VRM/VIN when the law allows us to. Most commonly, we will use your VRM/VIN in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those legitimate interests.
Where we need to comply with a legal or regulatory obligation.
We do not rely on consent as a legal basis for processing your VRM/VIN.

Purposes for which we will use your VRM/VIN

We have set out below, in a table format, a description of all the ways we plan to use your VRM/VIN, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your VRM/VIN for more than one lawful ground depending on the specific purpose for which we are using your VRM/VIN. Please contact us if you need details about the specific legal ground we are relying on to process your VRM/VIN where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To offer vehicle crash repair and repair related services (including for vehicle repair history look-ups, repair warranty related information, parts supply and parts procurement processes)	VRM and VIN	(a) Necessary for our legitimate interests (for running our business and offering crash repair and repair related services and solutions)
To administer, develop, and grow our and our business partners’ business and relevant products (including product development and enhancement, statistical and MI reporting, data analytics to improve our products/services, driving innovation and competition in the market place, and offering better, more efficient and more competitive products and solutions)	VRM and VIN	(a) Necessary for our and our business partners’ legitimate interests (for running, developing, and growing our and our business partners’ business and in driving innovation and competition in the market place by providing better and more efficient products and solutions over time.)
To prevent and aid public authorities (such as the police) in preventing and apprehending vehicle related fraud or crime, and to provide fraud prevention solutions to protect innocent parties from vehicle related fraud in the crash repair process and the market place.	VRM and VIN	(a) Necessary for our legitimate interests and the legitimate interests of third parties/public authorities (to prevent and apprehend fraud or crime and to protect innocent parties from being a victim of fraud or crime) (b) Necessary to comply with a legal obligation

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To offer vehicle crash repair and repair related services (including for vehicle repair history look-ups, repair warranty related information, parts supply and parts procurement processes)

VRM and VIN

(a) Necessary for our legitimate interests (for running our business and offering crash repair and repair related services and solutions)

To administer, develop, and grow our and our business partners’ business and relevant products (including product development and enhancement, statistical and MI reporting, data analytics to improve our products/services, driving innovation and competition in the market place, and offering better, more efficient and more competitive products and solutions)

VRM and VIN

(a) Necessary for our and our business partners’ legitimate interests (for running, developing, and growing our and our business partners’ business and in driving innovation and competition in the market place by providing better and more efficient products and solutions over time.)

To prevent and aid public authorities (such as the police) in preventing and apprehending vehicle related fraud or crime, and to provide fraud prevention solutions to protect innocent parties from vehicle related fraud in the crash repair process and the market place.

VRM and VIN

(a) Necessary for our legitimate interests and the legitimate interests of third parties/public authorities (to prevent and apprehend fraud or crime and to protect innocent parties from being a victim of fraud or crime)

(b) Necessary to comply with a legal obligation

No marketing usage

We do not use your VRM/VIN for any direct marketing purposes.

Change of purpose

We will only use your VRM/VIN 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 VRM/VIN for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your VRM/VIN without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your VRM/VIN

We may have to share your VRM/VIN with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your VRM/VIN and to treat it in accordance with the law. We do not allow our third-party service providers (if any) to use your VRM/VIN for their own purposes and only permit them to process your VRM/VIN for specified purposes and in accordance with our instructions.

6. International transfers

We are part of a global family of companies that together operate as Solera. Unless otherwise expressly agreed with the data controller, personal data may be transferred outside the European Economic Area (EEA) to other countries such as the United States, India, Mexico, Mauritius, North Macedonia and Belarus.

7. Data security

We have put in place appropriate security measures to prevent your VRM/VIN from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your VRM/VIN to those employees, agents, contractors and other third parties who have a business need to know. They will only process your VRM/VIN on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

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

To determine the appropriate retention period for VRM/VIN, we consider the amount, nature, and sensitivity of the VRM/VIN, the potential risk of harm from unauthorised use or disclosure of your VRM/VIN, the purposes for which we process your VRM/VIN and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for your VRM/VIN are available in our retention policy which you can request from us by contacting us.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your VRM/VIN. Please see Glossary below for a more detailed explanation about these rights:

Request access to your VRM/VIN;
Request correction of your VRM/VIN;
Request erasure of your VRM/VIN;
Object to processing of your VRM/VIN;
Request restriction of processing your VRM/VIN;
Request transfer of your VRM/VIN;
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us via the contact information set out above.

No fee usually required

You will not have to pay a fee to access your VRM/VIN (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 may refuse to comply with your request in these circumstances.

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 VRM/VIN (or to exercise any of your other rights). This is a security measure to ensure that VRM/VIN 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give the market place the best service/product and to drive competition and innovation. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your VRM/VIN for our legitimate interests. We do not use your VRM/VIN for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Comply with a legal or regulatory obligation means processing your VRM/VIN where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in the AUDATEX Group, acting either as joint controllers or processors, and provide IT and system administration services and undertake information reporting.

External Third Parties

Service providers acting as processors who provide IT and system administration services.
Parts supplier and providers, acting as joint controllers, who require VRM/VIN in certain circumstances for the parts procurement process associated with vehicle crash repairs.
Business partners, acting as controllers, who require VRM/VIN in certain circumstances for the legitimate interests of developing and enhancing innovative business solutions.
Data analytic and intelligence providers, acting as joint controllers, who require VRM/VIN in certain circumstances to develop analytic and intelligence solutions aimed at streamlining the crash repair, claims handling, and underwriting processes.
Public authorities such as the police, acting as joint controllers, who require data in certain circumstances to prevent or apprehend crime or fraud.

Your legal rights

You have the right to:

Request access to your VRM/VIN (commonly known as a “data subject access request”). This enables you to receive a copy of the VRM/VIN we hold about you and to check that we are lawfully processing it.
Request correction of the VRM/VIN that we hold about you. This enables you to have any incomplete or inaccurate VRM/VIN we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your VRM/VIN. This enables you to ask us to delete or remove VRM/VIN where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your VRM/VIN where you have successfully exercised your right to object to processing (see below) or where we are required to erase your VRM/VIN to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your VRM/VIN where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your VRM/VIN which override your rights and freedoms.
Request restriction of processing of your VRM/VIN. This enables you to ask us to suspend the processing of your VRM/VIN in the following scenarios: (a) if you want us to establish the VRM/VIN’s accuracy; (b) where our use of the VRM/VIN is unlawful but you do not want us to erase it; (c) where you need us to hold the VRM/VIN even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your VRM/VIN but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your VRM/VIN to you or to a third party. We will provide to you, or a third party you have chosen, your VRM/VIN in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you if any.
Withdraw consent at any time where we are relying on consent to process your VRM/VIN (if any). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.