Privacy Policy

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This policy (together with our app terms of use) applies to your use of:

• The Find That Asset Digital Web Application Software (App), once you have viewed a copy of the App onto your mobile telephone or computer (Device).
• Any of the services accessible through the App (Services).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please note: when a transaction is completed on our App, your personal data will be shared with the other person involved in that transaction (so that you can, for example, arrange the collection or the delivery of the item that has been bought). The other user will then be in control of your personal data as an independent controller.

This policy is provided in a layered format so you can click through to the specific areas set out below.

1. Who we are and how to contact us
2. Important information
3. The data we collect about you
4. If you fail to provide personal data
5. How is your personal data collected?
6. How we use your personal data
7. Disclosures of your personal data
8. International transfers
9. Data security
10. Data retention
11. Your legal rights

Who we are and how to contact us

Find That Asset Ltd is the controller and is responsible for your personal data (referred to as we, us or our in this policy).

If you have any questions about this privacy policy or our data protection practices, including any requests to exercise your legal rights, please contact us using the details provided, as follows:

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.

Important information

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 18 December 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

This App is not intended for children and we do not knowingly collect data relating to children.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: details about payments to and from you and details of in-App transactions.
• Device Data: the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use or time zone setting.
• Content Data: information stored on your Device, including photos, videos or other digital content.
• Profile Data: your username and password, in-App transaction history, your interests, preferences and feedback.
• Usage Data: details of your use of our App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: your current location disclosed by GPS technology.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide your personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

• Information you give us. This is information about you (including Identity, Contact, Financial, and Marketing and Communications Data) you give us by filling in forms on the App or by corresponding with us (for example, by email). It includes information you provide when you download or register the App, register an account with us, subscribe to any of our Services, search for an App or Service, upload an advert to the App, make an in-App purchase or complete a transaction and when you report a problem with our App or our Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using tracking technologies. Please see clause 6.5 for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Device Data from analytics providers such as Apple and Google based outside the UK (see clause 6.5 for further details);
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Inc. based outside the UK;
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances, where:

• you have consented before the processing;
• we need to perform a contract we are about to enter or have entered with you;
• it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
• we need to comply with a legal or regulatory obligation.

The types of lawful basis that we may rely on are:

1. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
2. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
3. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
4. Comply with a legal obligation means processing your personal data where it is necessary for compliancewith a legal obligation that we are subject to.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, 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 personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Tracking technologies

We use tracking technologies to distinguish you from other users of the App. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. By continuing to use the App, users are agreeing to our use of these tracking technologies.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use tracking technologies, over which we have no control. These are likely to be analytical/performance tracking technologies.

You can set your Device to refuse all or some tracking technologies. If you do this, please note that some parts of the App may become inaccessible or not function properly.

Change of Purpose

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.

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

Disclosures of your personal data

For the purposes set out in section 6.3, we may have to share your personal data with the following parties:

• External Third Parties such as:
• Other users of the App or Services acting as independent controllers based in the UK once a transaction between you and that user has been confirmed, in order for that transaction to be processed (e.g. your contact details so that delivery or collection of equipment can be arranged).
• Service providers acting as processors based in the UK who provide analytics, IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
• Specific third parties such as:
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degreeof protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

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

Our App includes chat features (e.g. allowing you to communicate with other users to discuss a potential or confirmed transaction). Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

We will generally retain data relating to historic transactions for a period of six years after a user ceases to be a customer, to ensure that we are able to assist should they have any questions or feedback in relation to the Services, for tax purposes, or to protect, or defend our legal rights.

Where we process your personal data for the purposes of marketing communications, we will keep your Identity and Contact data until you opt out of such marketing. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists.

In some circumstances you can ask us to delete your data: see clause 11 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data 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 personal data This enables you to ask us to delete or remove personal data 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 personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data 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 personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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

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 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 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.

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.

Find That Asset Ltd

Find That Asset Ltd is an IAR of Hire That Money Ltd which allows us to:

• Introduce regulated business to a broker.
• Distribute Finance Promotions in writing, advertise finance on websites and in the dealership.