Privacy Policy

1. Who we are

Manheim Ltd is the data controller in respect of any personal information to which this privacy policy applies. You can contact us at our head office address:

Manheim Customer Relations
Head office
Leeds Road
Rothwell
West Yorks.
LS26 0JE

Or you can email us: Customer.relations@manheim.co.uk 

Manheim Ltd is part of the Cox Automotive UK group of companies. The Cox Automotive UK Group consists of the companies listed below. References in this privacy policy to the ‘Cox Automotive Group’ should be taken to include all of these companies:

• Cox Automotive UK Ltd
• Cox Automotive Retail Solutions Ltd
• Manheim UK Ltd
• Nextgear Capital Ltd
• Motors.co.uk Ltd
• Dealer Auction Ltd
• Money4yourmotors.com Ltd
• Movex Logistics Ltd
• Kingfisher Systems Ltd
• RMS Automotive
• Modix UK Ltd


If you wish to contact our Head of Privacy & Data Protection, you can do so by emailing dataprotection@manheim.co.uk.

2. What we do with your personal information

Manheim Ltd collects and uses personal data relating to you such as name, address, email addresses etc when you complete registration forms or send emails to us. We may also record telephone calls made to telephone numbers included on our website.

In cases where you are seeking to open accounts with us which have a credit facility, we will conduct appropriate anti fraud and money laundering checks using publicly available sources such as press reports and credit reference agencies. We will share personal data relating to you with the other members of the Cox Automotive UK Group for direct marketing purposes.
The majority of the personal data we obtain about you is used for the purposes of administering your account and providing you with services relevant to the buying and selling of vehicles. We also user personal data for the purposes of sending direct marketing which may involve obtaining personal data about you from publicly available sources. This will generally be from your website or from publicly available directories.
We process personal data on the following legal grounds:

• Where you have consented to the processing, this will generally apply only to processing for direct marketing purposes. In such circumstances you can withdraw your consent at any time by contacting us by email or telephone.

• Where it is necessary for the performance of a contract, this will cover the majority of the processing we undertake with regards to providing you with the products and services requested from us and administering your account.

• Where it is in our legitimate commercial interests to process your personal data subject to your rights as set out later in this policy. Where the processing is not covered by either of the two grounds above it will be processed on this basis. 
We have a policy of only retaining your personal data for as long as we need it. We will retain personal data for as long as you have an active account with us and for as long as we are legally required to retain it once your account is closed. 

3. Disclosures and Transfers

Manheim Ltd will or may pass your personal information on to the following recipients:

• Employees and contractors of Manheim Ltd

• Other members of the Cox Automotive UK Group

• Third Party Suppliers operating on our behalf where necessary to provide you with the services you have requested

• Law enforcement agencies, Regulators and other investigative bodies where necessary for the prevention, detection or investigation of criminal or as required by law or otherwise to enable them to effectively carry out their functions

• We may transfer, sell or assign any of the personal information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business (or any part of our group).


4. Your rights in relation to your personal information

You have the following rights in relation to the personal information Manheim Ltd processes relating to you. Where you exercise these rights, Manheim Ltd will provide information to you as to what action has been taken, if any, within 30 calendar days of receipt of your request. Where no action has been taken, Manheim Ltd will explain our reasons why.
Taking into account the complexity and number of requests, it may take Manheim Ltd up to 90 calendar days to respond to your request. Where Manheim Ltd intend to extend the deadline for responding, you will be informed within 30 calendar days of receipt of your request. 

4.1 Right of Access

You have the right to request access to the personal information that Manheim Ltd hold about you.

4.2 Rights in relation to inaccurate personal information

Where personal information that Manheim Ltd holds about you is inaccurate, you have the right to request that those inaccuracies are rectified. Taking into account the purposes for which the personal information is processed, you also have the right to have incomplete personal information about you completed.

4.3 Right to erasure

In certain limited circumstances, you have the right to request that Manheim Ltd erase personal information relating to you that Manheim Ltd hold. This right only applies if any one of the following circumstances applies:

• Where Manheim Ltd no longer require the personal information for the purpose(s) for which it was obtained or otherwise used.
• Where the processing is based on your consent, that consent has been withdrawn and there is no other legal ground for processing.
• Where you have exercised your right to object to the processing and there is no overriding legitimate grounds for the processing.
• Where you have exercised your right to object to the use of your personal information for direct marketing purposes.
• Where the personal information have been unlawfully processed.
• Where Manheim Ltd are required to erase the personal information in order to comply with a legal obligation.

The right does not apply where the processing of your personal information is necessary:

• For compliance with a legal obligation requiring Manheim Ltd to process your personal information or where the processing is necessary for the performance of a task carried out in the public interest
• For the establishment, exercise or defence of legal claims.

4.4 Right to restriction of processing

You have the right to request that Manheim Ltd restrict the processing of your personal information in the following circumstances:

• Where you have contested the accuracy of the personal information. In this case the processing of the personal information will be restricted for a period which enables Manheim Ltd to verify the accuracy of the personal information in question.
• Where the processing of the personal information is unlawful and you have objected to the information being erased and have instead requested the restriction of its use.
• Where Manheim Ltd no longer needs the personal information for the purposes set out in part 2 above but you require them for establishing, exercising or defending legal claims.
• Where you have objected to the processing of your personal information as set out in section 3.6.1 below. In this case, processing of your personal information will be restricted pending verification of whether our legitimate grounds for continuing to process your personal information override your grounds for objecting.

Where processing of your personal information is restricted for any of the reasons above Manheim Ltd will not process it, with the exception of storage, unless:

• You have provided your consent,
• For the establishment, exercise or defence of legal claims,
• For the protection of the rights of another natural or legal person, or
• For reasons of important public interest.

Where Manheim Ltd have agreed to restrict the processing of your personal information, we will write to you to inform you that we will be lifting that restriction prior to doing so.

4.5 Right to data portability

This right only applies in the following circumstances:

• Where the personal information in question consists of information you have provided to Manheim Ltd,
• Where the grounds for processing the personal information stated in section 2 above are consent, explicit consent or for the performance of a contract or to take steps at your request prior to entering into a contract, and
• The processing of the personal information is carried via automated means.

Where this right applies, you have the right to receive your personal information in a structured, commonly used and machine readable format. You also have the right to transmit that information to another data controller or, where possible, directly from Manheim Ltd to another controller.

4.6 Right to object to processing

You have the following rights in relation to objecting to the processing of your personal information by Manheim Ltd:

• You have the right to object at any time, on grounds relating to your particular situation, to the processing, and
• The right to object specifically to the processing of your personal information for direct marketing purposes.

4.6.1 Right to object to processing

You have the right to object to the processing of your personal information at any time, on grounds relating to your particular situation. This only applies where the grounds for processing are:

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by a third party, or
• Processing is necessary for the performance of a task carried out in the public interest

4.6.2 Right to object to processing for the purposes of direct marketing

You have the right to object specifically to the processing of your personal information for the purposes of direct marketing. If you object to the processing of your personal information in this way, then Manheim Ltd will no longer process it for that purpose.

4.7 Rights in relation to automated decision making & profiling

You have the right not to be subjected to a decision based solely on automated processing, including profiling, which would legally affect you or significantly affect you. However, this right will not apply if the decision:

• Is necessary for the entering into, or performance of, a contract between you and Manheim Ltd
• Is authorised by or under any law to which Manheim Ltd is subject, or
• Is based on your explicit consent.

4.8 Right to complain to the Information Commissioner’s Office

Where you believe that Manheim Ltd has failed to properly comply with its obligations in respect of your personal information, including your rights as set out in section 3.1-3.7 above, you can complain to the Information Commissioner.
The Information Commissioner’s Office’s address is:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can find more information about their role and how to submit a complaint on their website: www.ico.org.uk.

5. Cookies

The law on cookies changed in May 2011. Under the revised regulations, the requirement is not just to provide clear information about the cookies but also to obtain consent from users or subscribers to store a cookie on their device. It has been designed to protect online privacy by making consumers aware of how personal information about them is collected by websites, and enabling them to choose whether or not they want it to happen. Please read on for more information.

What is a cookie? 
A cookie is a small piece of data that is sent from our web server to your browser, which is saved on the hard drive of your computer, smartphone or other device. 
A cookie cannot:
• read data off your hard disk or read cookie files created by other sites; 
• damage your system;
• run programmes on your computer; or
• deliver viruses. 
You can change your browser settings to refuse cookies or alert you when a cookie is being sent at any time. If you do choose not to accept cookies, some features of the Site may not work as intended (e.g. services accessed while logged in, customised areas of the Site). We do not use cookies to identify you personally, except when you opt to use the ‘Remember me’ facility when logging in.
There are two broad classes of cookie: session and permanent. 

Session cookies 
These are used to keep track of information needed by a user and their browser on their journey through a website. Session cookies have a short lifetime and expire within a few minutes of the user leaving the site. Occasionally we will use 30 Day cookies which are similar to Session cookies but last a bit longer. They remember basic data to help improve the service you receive from us (for example, remembering vehicles that you have viewed in the last 30 days).

Permanent Cookies
These are stored on your computer and are not deleted when the browser is closed. This is so they can retain your preferences for a particular website, allowing those preferences to be used in future browsing sessions.
Permanent cookies can be used to analyse users' surfing behaviour within the Site, so that we can improve our services and allows us to prioritise our enhancements to the Site.
What we use cookies for
• remember that you have used the Site before; this means we can identify the number of unique visitors we receive to different parts of the Site. This allows us to make sure we have enough capacity for the number of users that we get and make sure that the Site runs fast enough; 
• to keep you logged in for the duration of your visit, which enables you to complete certain actions on the Site, for example, move from one page to another within the Site, adding cars to a shortlist, using watchlists, viewing catalogues and using Simulcast.
• store your preferences or your user name and password so that you do not need to input these every time you visit the Site;
• customise elements of the layout and/or content of the pages of the Site for you;
• collect statistical information about how you use the Site so that we can improve the Site; 
• gather information about the pages on the Site that you visit, and also other information about other websites that you visit, so as to place you in a "market segment"; and
• enable basic web traffic analysis using Google Analytics.
We also use some cookies from trusted third party sources to enable us to provide you with certain features on the Site, for example our live chat facility which uses cookies to enable the chat software to work.
When you access the Site you will receive a message advising you that if you continue to use the Site, you are consenting to cookies being placed on your device in order to maximise your experience on the Site and allow us to make improvements
Removing some of our cookies may seriously disrupt your use of the Site. You can always come back to this Privacy Policy at any time to find out how to change your preferences. You will find a link to this policy at the bottom of all of our web pages.
Information is collected by reference to the IP address that you are using and includes information about the county and city you are in, together with the name of your internet service provider. The information is sometimes used to place interest-based advertisements on the Site which it is believed will be relevant to your market segment. For more information about this type of interest based advertising, and about how to turn this feature off please visit  www.youronlinechoices.com/uk/ . 
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Visiting www.allaboutcookies.org will provide information on settings within your browser as well as other useful information on cookies. Please note however, that by blocking or deleting cookies used on the Site you may not be able to take full advantage of the Site if you do so.

How do I disable cookies? 
You can change your browser settings to refuse cookies or alert you when a cookie is being sent at any time.   
Further guidance on how to control and delete cookies can be found at http://www.allaboutcookies.org. Please note that removing some of our cookies may seriously disrupt your use of the Site and some features may not work as intended. 
We do use some cookies from trusted third party sources to enable us to provide you with certain features on the Site and have included any relevant third parties on our cookie list so that you can control the cookies they place more easily:

Cookies list

Cookie

Content

Description

Expires

ASP.NET_SessionId

a 120-bit random number that is represented by a 20-character string

ASP.NET session ID

at end of browser session

__CSRFCOOKIE

a random 32 hexadecimal digits string

Used for protection against CSRF attacks

at end of browser session

cb-enabled

string

If an end-user has agreed with the cookies policy then this flag is set to 'accepted'

1 year

remarketing-web

encrypted sequence containing user access ticket

User authentication ticket - is created once user has successfully logged in

at end of browser session

Sitecore Analytics

SC_ANALYTICS_GLOBAL_COOKIE

To identify repeat visits from a single user, Sitecore sends a persistent session cookie to the web client. The name of the persistent session cookie is SC_ANALYTICS_GLOBAL_COOKIE.

one year after the last page requested from the solution by the web client

one year after the last page requested from the solution by the web client

SC_ANALYTICS_SESSION_COOK

To identify a sequence of HTTP requests from a single user, Sitecore sends an Engagement Analytics session cookie to the web client. The name of the session cookie is SC_ANALYTICS_SESSION_COOKIE. The value of the analytics session cookie before the first pipe character ("|") matches a value in the Visited column of the Visits table to identify an analytics visit record in the Analytics database.

when you close your browser

at end of browser session

Sitecore Backend - not populated for front-end users

scContentEditorFoldersWidth

Number

 

3 months

sc_fv

Text

 

at end of browser session

shell#lang

language code

 

at end of browser session

sitecore_starttab

Text

 

3 months

sitecore_starturl

URL

 

at end of browser session

sitecore_userticket

encrypted sequence containing user access ticket

 

at end of browser session

Cookie

Name

Purpose

Type and Duration

_ga

Google

Used to distinguish users.

2 years

_gat

Used to throttle request rate.

10 minutes

__utma

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

__utmt

Used to throttle request rate.

10 minutes

__utmb

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

__utmc

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

End of browser session

__utmz

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update

__utmv

Used to store visitor-level custom variable data. This cookie is created when a developer uses the setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

visitor_id

Pardot

Visitor Cookie: The visitor cookie includes the name “visitor_id” plus the unique identifier for your account,

10 years.

pi_opt_in

The persistent cookie named “pi_opt_in” is what we use to stay in compliance with the “Do Not Track” initiative

10 years.

Live Advisor

Live Advisor

This is used by the software to determine whether a visitor has been on the site before, for the purpose of identifying returning visitors (a visitor that deletes their cookies after a visit will not show as a returning visitor in live advisor).

The cookie does not store any specific visitor or visit information, as that is stored in the Live Advisor database.  

5 years

cb-enabled

 

Website

This cookie is created when user selects one of options on the cookie bar; Continue or Disabled. It is an identifier whether user is allowing to use cookie or not.

1 year

Remarketing-web

 

Website

We store this cookie to store user information securely by using standard cryptographic mechanism. We store information in cookie in order to set remember me and time out functionality



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