Privacy and Data Protection Notice
1. Policy Statement
1.1 Auto Imaging offers a subscription video & imagery solution to the automotive industry. Auto Imaging acts as a processor and processes the data provided to us to fulfil the service our customers have subscribed to.
1.3 Auto Imaging takes the issue of security and data protection very seriously and strictly adheres to guidelines published in the United Kingdom Data Protection Act and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018.
2. Status of the policy
2.1 This policy sets out our rules on data protection and the legal conditions that we will satisfy in relation to the obtaining, handling, processing, storage, transportation and destruction of personal information.
2.2 This policy is under regular review and the latest version of this policy is available on our website at all times.
3. Lawful Basis of Processing
3.1 Under the General Data Protection Regulation (GDPR) a company must have a Lawful Basis for Processing the data which they hold. Auto Imaging recognises our lawful basis for processing as;
3.1.1 Contractual. Upon signing our Order Form and other agreements which form the entire agreement, You or Your Organisation has given us contractual obligations to process the personal data provided to fulfil the services and provide support to individuals using our services.
3.1.2 Legitimate Interest. We have a legitimate interest in some of the data we hold and process. We need the data we collect and process to fulfil our working requirements such as building the products specific to You and assisting you with using our product. At all times we will produce Legitimate Interest Assessments in the event this Lawful Basis is used.
3.1.3 Consent. We send any marketing communications based on consent, and at all times you may unsubscribe or ask not to be contacted.
3.1.4 Legal. We have a legal obligation to hold accounting records which may contain personal information.
4. Information we collect
4.1 We will only collect personal data to the extent that it is required for the specific purpose notified to the Data Controller. Any data that is not necessary for that purpose will not be collected. You directly provide us with most of the data we collect. In our business operations we will collect and process the following data about you should it be provided:
4.1.1 Details of your visits to our Website and the resources that you access including, but not limited to, traffic data, location data, weblog statistics and other communication data;
4.1.2 Information that you provide by filling in forms on our Website, such as when you register to receive information such as a newsletter, an instant demo or contact us via the contact us page. Example information we collect by these means are, but not limited to, name, email address and phone number.
4.1.3 Information provided to us when you communicate with us via any means, for any reason.
4.1.4 Information provided to us on sign up to our services. This information will be provided to us by the dealership or OEM (employer) for us to input into the Product for use of our services. Example information provided to us by these means are , but not limited to, name, business or personal email address, business or personal phone number, address or contact details of your employer or address of place of work and job role.
4.1.5 Information updated or added in the Product at onboarding, such as names, email addresses, phone numbers or user names for accessing the Product. We may also collect information in the event you contact us to manage the user accreditations linked to the product.
4.1.6 Information collected or added throughout the usage of Our services, including Your customer information, as detailed in our contracts.
4.1.7 In the event of prospecting by our sales or marketing teams, we get this information from Prospects websites, bought databases, other entities within the CitNOW Group or through introductions. In the process of campaigning and prospecting, all data subjects will have the option to unsubscribe or have the right to be forgotten. For more information, You can email DPO@citnowgroup.com.
4.2 Auto Imaging has taken the necessary steps to ensure we do not knowingly process any child data by the confirmation of age button upon signing up for our Newsletter. We encourage you to advise us should you think a child has signed up to our newsletter by contacting us at DPO@citnowgroup.com and we will take the necessary steps to rectify this.
5. Use of your information
5.1 The information that we collect, process and store relating to you is used to enable us to provide our services to you, such as if you have signed up to receive marketing or if you are a user of our services, including offering you support as a user of our services.
5.2 We will only collect and process personal data for the specific purposes notified to the data controller when the data was first collected or for any other purposes specifically permitted by the applicable Privacy Law. This means that personal data will not be collected for one purpose and then used for another. Further processing for archiving in the public interest, scientific research or statistical purposes shall, in accordance with Privacy Law, not be considered incompatible with the initial purpose. If it becomes necessary for us to change the purpose for which the data is processed, we will inform the data controller of the new purpose before any processing occurs.
6.1 If you are an “Individual Subscriber” under the PECR, Auto Imaging will only send you the Auto Imaging Newsletter and other on brand marketing in regards to our products within CitNOW Group, should you sign up to this on our website or have given us your data and consented to receiving marketing via form of communication. Should we have your contact details, such as email address, from other means of communication we will not use this for marketing purposes. If you have agreed to receive marketing, you may always opt out at a later date by selecting unsubscribe or contacting us via the contact us section of our website.
6.2 Auto Imaging may send electronic marketing campaigns to Corporate Subscribers, under the PECR definitions and within the regulations as described, but at all times will facilitate unsubscription by such Corporate Subscribers.
6.3 You have the right at any time to stop Auto Imaging from contacting you for marketing purposes. You can do so by clicking the “Unsubscribe” button on the received emails.
7. Storing and destroying your personal data
7.1 We store your data on secure servers inside the European Economic Area (EEA). Some of our subcontractors are based outside of the EEA, however we have the currently necessary safeguards in place to ensure safe processing. A list of our subcontractors is available on request.
7.2 Data that is provided to us is stored on secure servers. Any personal information held in AutoImaging databases is encrypted at rest with industry-standard AES-256 encryption. Access to the servers is restricted to those users who require access for maintenance and development and is secured by multi-factor authentication.
7.3 The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our product, you are responsible for keeping this password confidential.
7.4 Personal data will not be kept longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems in a safe way when it is no longer required. For guidance on how long certain data is likely to be kept before being destroyed, you can request this by emailing us at DPO@citnowgroup.com.
8. Disclosing your information
8.1 If required to fulfil the services and in line with the purposes of processing, we may disclose your personal information to any member of our group (“CitNOW Group”). This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries.
8.2 We may disclose your personal information to third parties under the following circumstances:.
8.2.2 to protect the rights, property, or safety of Auto Imaging, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
8.3 We only disclose your information to our subcontractors as far as is necessary to provide our service. We complete all the necessary security checks and due diligence to ensure that your data is kept safe with third parties. The subcontractors only have the right to use your data to complete an obligation, they do not have marketing rights over your data. Your data may be used in the following other third party circumstances:
8.3.1 We may contract a data cleansing organisation to ensure all data is accurate and up to date.
8.3.2 All phone call recordings and messages are kept by a third party who only have processing rights to fulfil the service over your data and will not contact you.
8.3.3 Where We sell any or all of our business and/or our assets to a third party.
8.3.4 Where Our Customers have signed up for a service offering which integrates with a third-party application. In this instance the data will flow through the application to fulfil the service, and the owner of the application will have access to this data, including the content, and will be a joint data controller.
8.4 You may find links to third party websites on our website. These third parties have their own privacy policies within their websites which we advise You to check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
8.5 Any information captured from the website, including forms and newsletter sign up, is sent to our UK Company in the first instance. This means, our UK Company is the processor of the data from the website. As such, if you are subscribed to our service through one of our EU Entities, the data is sent to them via the UK Head Office. The customer portal website is hosted on Amazon Web Services (AWS). Our Website is hosted by Paragon Internet Group Ltd t/a Tsohost.
9. Accurate data
9.1 Personal data must be adequate, relevant, limited to what is necessary for the specific purpose and kept up to date. If we identify information that is incorrect, misleading or is not accurate we shall take steps to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data will be destroyed. If you identify any data that we are holding which is incorrect, misleading or inaccurate, please advise us and we will take the necessary action to correct this.
10. Your data protection rights
10.1 Auto Imaging would like to make sure you are fully aware of all of your data protection rights. Every user may be entitled to the following rights, subject to refusal in circumstances outlined by the Supervisory Authority :
The right to access – You have the right to request Auto Imaging for copies of your personal data.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request Auto Imaging to complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Auto Imaging restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Auto Imaging’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:
Telephone: 0118 997 7740
Postal: 9 Millars Brook, Molly Millars Lane, Wokingham, Berkshire, RG41 2AD
11.1 Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. On occasion, we may gather information about your computer for our services. Such information will not identify you personally, it is statistical data about our visitors and their use of our site and does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with the Website or our Product so that we can continue to develop and improve it and make your browsing experience more useful, more relevant and tailored to you.
11.2 Some of the cookies we use will expire after you close the browser window. These are called session cookies. Some cookies last longer than this, because they are used to identify return visits to the website, for such data as keeping you logged in or for remembering your previously selected preferences.
11.3 Please see below a breakdown of cookies we use on our website and their expiry periods: