Welcome to the HPI Limited’s privacy notice.
HPI Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) or use our services at https://hpivaluations.com/, https://hpicheck.com, https://hpi.co.uk or our other sites and services (altogether “Websites and Services”) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a sectional format. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how HPI Limited collects and processes your personal data through your use of our Websites and Services, including any data you may provide through the Websites and Services when you sign up to our newsletter, purchase a product or service or take part in a competition.
The Websites and Services we operate are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice, consent notice, or fair processing notice we may provide on specific occasions from time to time when we are collecting or processing personal data about you 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.
HPI Limited is the controller and responsible for your personal data (collectively referred to as ”HPI”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entity: HPI Limited
Email address: firstname.lastname@example.org
Postal address: Bond Court, Leeds, LS1 5EZ, United Kingdom
Telephone number: 0113 222 2010
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 and your duty to inform us of changes
This privacy notice may be updated by us from time to time. This version was last updated on October 2019. The most up-to-date version of the Privacy Notice can be found at www.cap-hpi.com.
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 your relationship with us.
The Websites and Services may include links to third-party websites, plug-ins and applications not operated by us. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy statements. When you leave our website, we strongly encourage you to read the privacy notice of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
2.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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data generally includes, to the extent applicable: name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data generally includes, to the extent applicable: billing address, delivery address, postcode, email address and telephone numbers.
- Financial Data generally includes, to the extent applicable: bank account and payment card details.
- Transaction Data generally includes, to the extent applicable: details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data generally includes, to the extent applicable: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data generally includes, to the extent applicable: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data generally includes, to the extent applicable: information about how you use our website, products and services.
- Marketing and Communications Data generally includes, to the extent applicable: your preferences in receiving marketing from us and our third parties and your communication preferences.
In addition We may collect, use, store and transfer the Vehicle Registration Mark ("VRM"), and Vehicle Identification Number ("VIN") of a vehicle.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.
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 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3.How is your data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, Profile, Marketing and Communications Data, and VRM/VIN among others by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for, inquire about, or purchase our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you or VRM/VIN from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based inside the EEA;
- advertising networks; and
- search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and PayPal.
VRM/VIN from our partners such as the Driver and Vehicle Licensing Agency (DVLA), finance houses, vehicle dealers, and our customers.
- Direct interactions. You may give us your Identity, Contact, Financial, Profile, Marketing and Communications Data, and VRM/VIN among others by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
4.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 we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. In such cases we will obtain your explicit consent for such activities, and you will have the right to withdraw consent to such marketing at any time by following the unsubscribe link in marketing messages or by contacting us.
Purposes for which we will use your data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and 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 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.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer
Performance of a contract with you To process and deliver your order and/or providing services to you including:
- Manage payments, fees and charges
- Collect and recover money owed to us
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
- Asking you to leave a review or take a survey
- Marketing and Communications
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you including goods and services similar to the ones you have purchased or inquired about
Necessary for our legitimate interests (to develop our products/services and grow our business) To prevent and aid public authorities (such as the police) in preventing and apprehending fraud or crime, and to provide fraud prevention services
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) To administer and provide our warranty services with respect to the accuracy of vehicle data and to establish and prove losses, damages for the purpose of warranty claim processing and settlement
Necessary for our legitimate interests and the legitimate interests of third parties/customers (for the processing of warranty claims and for the establishment, proof, and settlement of warranty claims) To provide our National Mileage Register (“NMR”) related services and for conducting NMR investigations on vehicles
Necessary for our legitimate interests and the legitimate interests of third parties/customers/public authorities (for the purposes of conducting NMR and mileage investigations to ensure the accuracy of the mileage reading on vehicles and to prevent fraud) 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
- Necessary for our and our business partners’ legitimate interests (for running, developing, and growing our and our business partner’s business and in driving innovation and competition in the market place by providing better and more efficient products and solutions over time.)
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you, and to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the HPI group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe link in those marketing messages or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not affect our processing of your personal data for other non-marketing purposes such as providing a product/service to you, warranty registration, product/service experience or other transactions, etc.
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.
Third party payment processors
The payment processors we partner with are:
5. Disclosures of your personal data
We may have to share your personal data or 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.
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 notice.
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. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
6. International transfers
We do not transfer your personal data or VRM/VIN outside the UK, European Economic Area (EEA) and Switzerland except in accordance with the data protection law and where appropriate safeguards as approved by the data protection law has been put in place.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
HPI recognises the importance of secure online transactions, and we safeguard the privacy of information provided to us through online forms. We use a Digital Certificate to assure you of the validity of our site and for consumer requests submitted to us online, we use Secure Sockets Layer technology to provide strong encryption for the data you provide on the order form before transmission to HPI.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
More specifically, and without limiting the generality of the foregoing, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers for tax, financial auditing, and record keeping purposes.
In some applicable circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Glossary below for a more detailed explanation about these rights:
- Request access to your personal data;
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing your personal data;
- Request transfer of your personal data;
- 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 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you and the market place 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.
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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the HPI Group, acting either as joint controllers or processors, and who are based in the UK, Switzerland, and EEA and provide IT and system administration services and undertake information reporting.
External Third Parties
Service providers acting as processors based in the UK, Switzerland, and EEA who provide IT and system administration services.
Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK, Switzerland, and EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the United Kingdom who require reporting of processing, financial, or transaction activities in certain circumstances.
Public authorities such as the police, acting as joint controllers, based in the United Kingdom who require personal data in certain circumstances to prevent or apprehend crime or fraud.
Business partners, acting as controllers, based in the UK, EEA and Switzerland 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 controllers, based in the UK, EEA and Switzerland who require VRM/VIN in certain circumstances to develop analytic and intelligence solutions aimed at streamlining the crash repair, claims handling, and underwriting processes.
Your legal rights
You have the right to:
- 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.