PRIVACY NOTICE FOR CLIENTS AND BUSINESS CONTACTS

This privacy notice describes how CAROUS LIMITED (“we” or “us“) uses personal data relating to our clients, suppliers, website visitors and other business contacts. It also
describes our direct marketing activities relating to existing and potential clients, and how we use cookies on our website. Individuals whose data we collect and use are referred to in this notice as “you“.

We may update this notice from time to time. It was last updated in [July 2024].

This notice is set out in the following sections.
1. Who we are

2. What data we collect and how we use it:
    ● Our clients
    ● Our suppliers and service providers
    ● Enquirers and other business contacts
    ● Google Analytics and use of cookies
    ● Marketing communications and social media
    ● Use of data for other standard business purposes
    ● Sensitive personal data

3. Sharing your data
    ● Our service providers
    ● Other parties
4. International data transfers

5. Retaining your information

6. Your rights, including your right to access a copy of the data we hold

7. Our activities as a processor (on behalf of our clients)

8. Our contact details
   1. WHO WE ARE
CAROUS LIMITED is a company registered in England and Wales with company registration number (15180341). We provide website design, ecommerce solutions and marketing services in the automotive industry.

You may contact us with any queries or concerns about our use of your data, and to exercise your data protection rights (see section 6 below). Our contact details are set out at section 8 below.
    ● Our activities as a controller: We act as a ‘controller’ for the purposes of data protection laws in our use of your data for our own business purposes. This means that we determine how and why your data is collected and used, for example in managing client and business relationships, marketing our services, dealing with enquiries, and running our business.
This notice is primarily about our activities as a controller, and more information is provided in sections 2 to 6 below.
   ● Our activities as a processor: In providing our services, we also hold some personal data as a ‘processor’ on behalf of our clients, which means such data is used for purposes determined by our clients, and they are primarily responsible for how such data is used. This includes, for example, our use of information about individuals on or collected via client websites which we design or host, and as part of client marketing activities which we facilitate as part of our services. Some information about these activities is provided at section 7 below.

Note: Our clients are responsible for providing further information about these activities, ensuring individuals are made aware of how their details are being used, and obtaining
any required consents.

2. WHAT DATA WE COLLECT AND HOW WE USE IT
   1. Our clients
We hold personal data relating to our contacts at organisations who are our clients. Such personal data typically includes:

   ● Name.
   ● Role within client organisation and other business information relating to your role.
   ● Contact details (including business postal address, email address and telephone number).
   ● Login details for our dealer management system.
   ● Other personal data (including any private details provided) within communications with you or your organisation.
We use your data in order to manage our relationship with you and your organisation, and to administer our services to clients. This includes sending you service updates, for example to let you know if our systems are having any downtime. We may also send you our newsletters (though you may unsubscribe at any time).

Our legal basis under data protection law for using your personal data is our legitimate interests in carrying out the activities described above. 

We generally obtain these details directly from you or the organisation for whom you work. In some cases, initial contact details or information may be obtained from other parties who have recommended you as a client, or from other business sources, such as information provided on your organisation’s website or within social media (such as LinkedIn) for business purposes. See also section 2.5 below about direct marketing and connecting on social media.

Note: if you provide us with information relating to other individuals (such as other staff within your organisation or recommended contacts), you must ensure that disclosure of
this personal data to us does not contravene data protection requirements.

   2. Our suppliers and service providers
We hold personal data relating to our contacts at organisations which supply or may supply us with goods or services. Such personal data typically includes:

   ● Name.
   ● Contact details (including business postal address, email address and telephone number).
   ● Personal data within communications with you or your organisation.
   ● Finance and billing details (for example where you are self-employed or a sole trader).
We use these details to manage our relationship with you or your organisation, and to administer matters relevant to the goods or services being provided.

Our legal basis under data protection law for using your personal data is our legitimate interests in carrying out the activities described above (or, if you are self-employed or a
sole trader, that we need such details in order to perform our contract with you).


    3. Enquirers and business contacts
Other business contacts may include enquiries or visitors to our website or business, or people who contact us over social media. Personal data which we hold typically includes:
    ● Name.
    ● Contact details (as relevant to your enquiry or visit).
    ● Information specific to your enquiry or visit (or other relevant contact), including information you provide in the enquiry box on our website.
    ● Personal data within communications with you.
We use such details for the purpose of handling or administering your enquiry or visit, and as may be relevant to the circumstances of our relationship with you.

Our legal basis under data protection law for using your personal data is our legitimate interests in carrying out the activities described above.

    4. Google Analytics and use of cookies
    ● Website analysis: We use Google Analytics to collect standard internet log information and details of visitor behaviour patterns. This assists us to understand how visitors engage with our website, by looking at statistics such as the number of visitors to the various parts of the site at different times. Google Analytics uses cookies in order to obtain this information. This information is processed by us in a way which does not seek to identify anyone.
    ● Functional cookies for form submission: We use Google ReCaptcha for form submissions to protect our website from spam and abuse. Google ReCaptcha uses cookies in order to provide this service. Except to the extent they are strictly necessary for the provision of our services, cookies will only be used if we obtain your consent. You will be given options when you first visit our website and can change your preferences at any time. If you do not provide your consent, you may not be able to use certain aspects of the site (such as communicating with us by completing a webform). You can also disable cookies using your browser’s privacy settings. More information about our use of cookies is set out in our Cookies
Notice.
    5. Marketing communications and social media
    ● Consent to direct marketing: if you contact us with an enquiry (for example on our website or over social media), we may request your consent to contact you in future for marketing purposes.
    ● Referrals from other parties: We may obtain your contact details from another party who has recommended you as a potential client, for example because you have shown an interest or otherwise indicated that you may need services such as those provided by us. In these cases, we may make initial contact with you to discuss our services (in our legitimate interests in engaging with new clients and marketing our services).
    ● Social media groups: With your consent, we may add you to a social media or communications group, such as over WhatsApp. We may obtain your consent directly or, if your details are provided to us by another person, we shall ask them to check you agree before providing your details to us.
    ● Connecting on social media: We may connect with you or follow you on social media, in order to keep up to date with your activities and business issues of interest (in our legitimate business interests).
You may request at any time that you do not receive direct marketing communications from us using the contact details at section 8 below.

Note that, where you choose not to receive marketing communications, we may still use your contact details to communicate with you in relation to matters relevant to our relationship with you, such as customer service communications (if you are a client).
    6. Use of data for other standard business purposes
Your personal data may also be used by us:
    ● to maintain appropriate records of our business communications and relationships (in our legitimate interests); and
    ● to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).
    7. Sensitive personal data
    We do not generally hold sensitive categories of data about clients and other business contacts described above (for example, information about health, racial or ethnic origin,
or criminal convictions). If any such data becomes relevant (for example if you provide us with information about any special needs which you have relevant to our relationship), we will assess our legal responsibilities at that time and, where appropriate, provide you with additional information about how we may use such data.

    3. SHARING YOUR DATA
        1. Our service providers
Our service providers may handle your data, such as our data centre and technology service providers. They act as processors on our behalf, meaning that we remain primarily responsible for how they use your data on our behalf in line with the purposes and legitimate interests identified in section 2 above.
        2. Other parties
We may also share your data, where relevant, with the following parties

        ● legal authorities or regulatory bodies;
        ● our legal or other professional advisers;
        ● prospective or actual purchasers of our company or business;
        ● other parties to the extent needed to progress an enquiry or request from you, or to provide a service requested by you or your organisation, or if you have consented to us doing so; and
        ● other parties where we are otherwise required or permitted by law to do so (including by data protection law). Our legal bases for such data sharing are, as appropriate, our (or the recipient’s) legitimate interests in the relevant activity, compliance with a legal obligation, or your consent.

    4. INTERNATIONAL DATA TRANSFERS
At the date of this notice, we do not transfer your data outside the UK and the European Economic Area (within which organisations are subject to the UK GDPR or the EU GDPR, which provide protection for and give you rights in relation to your personal data). However, we may have members of our organisation, based outside the UK & EU where data may be transferred to conduct relevant activities based on services provided.

    5. RETAINING YOUR INFORMATION
We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures. Please contact us (using the contact details at section 8 below) for further information about these.

    6. YOUR RIGHTS
In accordance with data protection laws, you have certain rights in relation to our use of your personal data. These rights include the following:
    ● to obtain a copy of the personal data we hold about you, together with other information about how we process it (known as a subject access request);
    ● to withdraw any consent which you have given relating to the use of your data;
    ● to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your particular situation;
    ● where our use of your data is based on your consent or necessity for our contract with you (described as the ‘legal basis’ in the relevant sections above), to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation;
   ● not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met; and
   ● to make a complaint about how we handle your data to the UK Information Commissioner’s Office. Please visit www.ico.org.uk for further information about how to do this (and further guidance on your rights).
Please contact us (see section 8 below) to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about these and other rights which you have.

Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.

    7. OUR ACTIVITIES AS A PROCESSOR

Note: Our clients have primary responsibility to ensure Carous’s use of the information as outlined in this section complies with data protection and privacy laws. If you have any queries about use of your data for these purposes, they should be directed to the relevant client.

    1. Client websites, CMS and DMS
    ● We design and host content of our clients’ websites, which may provide information about individuals, handle enquiries from individuals, make sales to individuals, assist in handling payments for clients, and have other interactive content. They may also use cookies to collect information about use of the website.
    ● We store and process information from or relating to those websites within our content management and dealer management systems (CMS and DMS).
    ● We may send clients by email details of leads which have been captured by their websites.
In these cases, we collect, use and store (and share with our clients) personal data and related information on behalf of our clients, for the purpose of providing these services.
Such personal data may include names, telephone numbers, email addresses, content of enquiries, details of sales, data collected by cookies, and other content of communications.

    2. Marketing communications
We provide marketing services to our clients, in which case clients may provide us with their marketing lists (including names and email addresses), and we send out marketing
communications on their behalf. This also involves our use of personal data of individuals on such marketing lists on behalf of our clients, for the purpose of providing these services.
    3. Our service providers
In providing the services described above, our service providers may also handle our clients’ data (including your personal data), such as:
   ● our data centre and technology service providers; and
   ● mailing or communications service providers
   8. OUR CONTACT DETAILS


Post: CAROUS LIMITED, OFFICE 126, REGUS, CONCORDE PARK, CONCORDE
ROAD, MAIDENHEAD, SL6 4BY


Email: [email protected]

CAROUS

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