We’re removing the faff from changing and managing vehicles, and we also want to make our legal documents a cinch for anyone to understand. If you have any doubts or suggestions regarding any of them, please contact us and we’ll do our best to help.
If you decide to enter your data, create an account, or ask to be put in touch with a dealer, then the idea of this Notice is to help you understand fully what data we have, how we use it, where it goes, and your rights to decide what happens with it. We will use personal data about you only for the reasons that you provided it, and in line with all applicable laws and what’s explained in this Notice.
This Notice may change from time to time, for example because of developments in technology, our business, or the law, so please check back when you visit cinch for the most current information.
This Notice is primarily aimed at cinch users. If you are a current or potential cinch advertiser or supplier, please see Section 8. If you are a cinch staff member please speak to your manager or HR department.
1. Who is the data controller for your data?
A “data controller” is the organisation that decides on the purposes and ways that your personal data is processed. cinch’s website and services are provided by, and these decisions are made by:
Cinch Cars Limited
Farnham GU9 7XG, UK
cinch is part of the BCA Marketplace plc group of companies, who have created a “privacy office” and appointed a data protection officer to answer enquiries related to personal data processing.
2. Why do we process personal data? What data do we process? And what is our legal basis for that processing?
If you are a cinch user, cinch needs to process personal data about you for the following purposes:
- Improving your search results: You aren’t obliged to provide any personal data but in order to improve the matches of the vehicles we’ll show you, you are able to enter the following:
o People you live with (number and approximate ages)
o Number of pets
o Frequency and types of journey you usually make (e.g. short local trips or longer journeys)
o Budget levels you are considering
o Relevant health data (e.g. whether you might need a vehicle that is accessible for a wheelchair user or is adapted for driving by someone with a disability)
o Relevant hobbies and interests (e.g. whether you need a vehicle that could hold a bike, skis or a surfboard).
- Creating and managing your cinch account: You still aren’t obliged to provide any personal data (except for an email and password) but in addition to the above you are able to enter the following:
o Phone numbers
You can edit this data by logging into your account.
- Having dealers answer your enquiries: If you indicate that you are interested in one of the vehicles that a dealer has advertised on cinch, then you may call them using the phone numbers provided or email them directly through the site. You may also ask for a callback, or to be contacted by email or text message: we’ll need to provide the dealer with your relevant details, so that they can do this. Please note we’ll record calls and keep records of them and the contents of emails in order to ensure that your enquiries are properly dealt with, that our billing is correct, and to improve our services.
- Providing customer service: If you contact us with a query or complaint, then we will collect and process your details and keep records of our interactions with you (e.g. calls, emails, chat sessions, letters), as needed to investigate and provide you an answer.
- Running promotions, contests or prize draws: If we run a promotion, contest, or prize draw then we will collect and process your details in order to manage your entry. We may at the same time give you the opportunity of signing up for an account or newsletter but will only use your data for that purpose if you accept.
- Sending newsletters/offers: If you subscribe to newsletters or other offers or information from us then we’ll use your data to tailor and send these to you, until you change or cancel your subscription or contact preferences.
Our legal basis for all the above is your consent. We want you to provide your data in full knowledge of what we will use it for, where it will go, and your rights as set out in this Notice. Where you’ve given your consent, you can change your mind at any time by contacting us (although any processing of the data that took place before you do so will still be legal). If you provide personal information about others (e.g. people who live with you) then you should make sure that you have their consent too.
- Service communications: We may need to contact you in relation to service-related issues, e.g. forgotten account details, technical issues with the service, updates to terms and conditions, or other non-promotional messages.
- Quality control: We will keep a record of all calls (or other requests you make for contact from a dealer) so we can follow up and check that you got good service, investigate any issues, and ensure that our bills to dealers for our services are correct.
Our legal basis for these data uses is that they are necessary for our legitimate interests in ensuring that cinch users get good service, understanding how people use cinch, and improving it for the future. We don’t use this data to contact you or market anything to you. It’s used securely, and not in any intrusive way. There is no negative impact on your privacy or rights and so we have concluded that we are able to process this data to support our legitimate interests.
“Special categories of data”: Under data protection laws, personal data concerning health is a “special category” of data that is subject to additional protections. This type of data may be very helpful with searches, as noted above, to help you find vehicles that suit the needs of anyone with a disability, e.g. if you needed access or storage for a wheelchair, or a vehicle adapted with hand controls. We only process this type of data with your explicit consent.
cinch does not intend to collect or process any other special categories of personal data e.g. those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, certain genetic data or biometric data, or data concerning a person’s sex life or sexual orientation. However, if you add any such details to your profile or communications on cinch, then you are consenting to using that data for those purposes.
3. How long does cinch keep your data for?
cinch doesn’t keep your personal data for any longer than necessary. If you have signed up for an account with cinch, then you will be able to access it and we will keep your personal data within it until you change it or cancel your account.
If you make an enquiry in relation to a vehicle, then we will keep data relating to that enquiry for as long as necessary to send invoices to our dealers, understand whether your contacts with dealers were satisfactory, and resolve any outstanding questions.
If we need to keep your data longer for tax, accounting, reporting or legal reasons then we will use it only for those purposes and for a period that is reasonably necessary to comply with the laws and policies that apply to us and to be in a position to deal with any legal claims.
After these periods we anonymise data (so it does not contain any personal information and cannot be traced back to you) but will keep and use it for research or statistical purposes and improving our website and services.
4. Does cinch provide your personal data to any third parties?
If you indicate that you are interested in a vehicle advertised on cinch, then depending on the contact method you choose, we may provide your contact details and other relevant details relating to your vehicle search and account to the relevant dealer so that they can respond to your enquiry and understand your needs.
From time to time we may provide additional services on our website. So for example, if we offered a servicing or valeting option, and you indicated you were interested then, again depending on the contact method you choose, we would need to provide your contact details to the service provider.
cinch also works with other organisations that provide services such as IT and data processing or other professional advisors. These include:
- providers of IT-related services (e.g. data storage, website development, hosting, management, or maintenance);
- other data processing companies that provide us with services such as call and email tracking and recording, management of PR and customer communications, sending emails or texts, or processing of information or newsletters;
- companies in our group that provide us with additional technical infrastructure or services;
- data analysis providers (e.g. measuring which webpages or advertisements are of most interest); or
- accounting, legal, insurance or banking service providers.
These organisations process personal data on our behalf, but our contracts with them oblige them to meet data protection standards as strict as the ones that apply to us, and not to use your data for any other purpose.
Where these are not based in the UK, the EU, or other countries that are officially regarded as having adequate data protection laws, then this will be done only on the basis of legal safeguards aimed at ensuring that your data is kept as secure as under applicable UK and international laws. These may include the European Commission’s standard contractual clauses for data exports, or the EU-U.S. Privacy Shield. A copy of such safeguards may be available from us if we receive a valid request.
Other circumstances where cinch may need to disclose your personal data to third parties could be (i) where required by law, stock exchange rules, or any governmental authority, police force, court or regulator; or (ii) in connection with a sale or merger of our business or company.
5. What about other websites?
cinch’s aim is to become a point of support in all phases of changing or managing your vehicle and so we will often provide links to other websites offering relevant services or information.
For example, in order to obtain a valuation of your vehicle, and commence a possible sales process you may be directed to webuyanycar.com. From time to time we may also provide links relating to other services that are relevant to changing and managing your vehicle.
6. What are your rights in relation to your personal data?
cinch is committed to ensuring that you can easily exercise your legal rights over your personal data under UK and international laws that apply to us.
For example, you are entitled to ask at any time:
(a) for access to a copy of the personal data that cinch holds about you;
(b) to have any incorrect personal data about you corrected;
(c) for data about you to be erased (also referred to as the “right to be forgotten”) or if that is not possible (e.g. because the law requires us to keep data for longer) to have processing restricted:
(d) to object to particular processing (e.g. for marketing purposes);
(e) to receive an electronic copy of data you provided to us, for provision to a different service provider (also referred to as “data portability”).
You are also able to withdraw any consent given in the past.
If you receive any marketing information from cinch and wish not to receive such information in future please email us at email@example.com. You will also have the opportunity to opt out of future communications whenever cinch sends you any such material.
cinch can always be contacted at the addresses in Section 1 to resolve any issues or doubts you may have in relation to processing of your data, or exercising your legal rights. If you believe that your rights have not been respected then you are also entitled to complain to the UK Information Commissioner (www.ico.org.uk) (or outside the UK, the Supervisory Authority in your country) to ask them for a decision.
7. Do you have to provide your personal data to cinch?
cinch is free to use and you aren’t required to sign up for an account or enter any other data if you don’t want to.
8. cinch business contacts
cinch will also need to process your personal data if we have or are considering a business relationship with you, for the following purposes:
As this data always relates to your professional life (work email, work telephone, information about contracts etc.) and/or is obtained from sources where it is voluntarily offered (e.g. websites, trade shows, or professional networking) there will be no negative impact on your privacy or rights, and our use is within what a professional data subject would reasonably expect.
Although applicable laws do not require us to obtain your consent for such data processing, you may still be entitled to exercise your legal rights where applicable (see Section 6 above).
We regularly review and update the need for retaining such data and will normally delete such data after six years from the end of any contractual relationship, unless we are required to retain it for compliance purposes or to resolve any legal issues.
Like almost all websites, cinch uses 'cookies' that store information to help us understand the use of our services and to make them easier to use. This policy is designed to tell you about the cookies we use on our website.
A cookie is a small file that our website may place on your device and which can be useful for recognising you as a returning visitor, saving settings and providing us with information about how the website is used. Some cookies are required so the site can work but other than those, you are not obliged to accept cookies, and you have the ability to accept, decline or delete cookies using the settings in your web browser.
www.allaboutcookies.org provides further information about cookies and also how to use settings to manage them on different type of devices.
cinch uses the following types of cookies:
“Essential cookies” – these are needed in order to enable you to move around the website and use all its features. Without these cookies, some features cannot be provided – for example, remembering previous actions or saved items, or keeping you logged in while browsing.
“Analytical or Performance cookies” – these gather information about how cinch is used, for example, how many users visit different pages, how long they spend there, the items they click on, or how they arrived at cinch (e.g. from an advert or social media). These cookies are only used to monitor, test, and improve ease and speed of navigation, and analysing cinch’s marketing activities.
“Functional cookies” – These are used to recognise you when you return to our website. They enable information you enter to be saved for your next visit (such as your username or postcode), so that you don’t need to re-enter it and any personalised features are remembered.
“Retargeting cookies” – these cookies are used to remember that you have visited cinch in the past and may enable cinch adverts or other adverts relevant to you to be shown to you on other sites you visit later. They are also used to limit the number of times you see an advertisement, and measure views, clicks and purchases.
Some cookies are provided to us by third parties who provide services to us. In particular these cookies are used in order to record which vehicle ads you have viewed and whether you have called, emailed or requested a contact from a dealer; and your interactions with our customer services e.g. by chat or email. These third parties use this information only to provide services to us – we don’t permit them to reuse the information for their own purposes or to provide it to their other clients.
Last updated: 17 June 2019
Copyright © cinch, first published in 2019, no copying or any other use is allowed