MOGO Privacy Policy

Introduction
We are committed to protecting and respecting your privacy.
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 read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on the processing of personal data are set out in the UK General Data Protection Regulation (the "UK GDPR") and the Data Protection Act 2018.

1) Definitions
Data controller — A controller determines the purposes and means of processing personal data.
Data processor — A processor is responsible for processing personal data on behalf of a controller.
Data subject — A natural person.
Categories of data — Personal data and special categories of personal data.
Personal data — Any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier. For example, name, home address, email address or telephone number. Online identifiers include IP addresses and cookies.

Special categories of personal data — Sensitive personal data, including genetic and biometric data processed to uniquely identify an individual, as well as racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, and religious or philosophical beliefs.

Processing — Any operation performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, alignment, restriction, erasure or destruction.
Third party — A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2) Who are we?
MOGO is a brand operated by New Auto Ltd.
New Auto Ltd is the data controller. This means we decide how your personal data is processed and for what purposes.
Our contact details are: New Auto Ltd, Unit 9 Springlakes Estate, Deadbrook Lane, Aldershot, Hampshire, GU12 4UH.
For all data matters, contact our Data Protection Officer, Trevor Gray, at trevor.gray@sandhurstautoprint.co.uk.

3) The purposes of processing your personal data
The MOGO website is an informational and enquiry-based site. We use your personal data for the following purposes:

• To respond to your enquiries and prepare quotes, including trade enquiries from taxi drivers, fleet operators and Local Authority licensing teams.

• To send marketing communications where you have agreed to receive them, or where we are otherwise permitted to do so.

• To understand how our website is used and to improve our content, service and online experience.

• To protect our website and prevent spam and fraud.

4) The categories of personal data concerned
With reference to the categories described in the definitions section, we process the following categories of your data:
Processing necessary to take steps prior to a contract, or in our legitimate interests

• Handling of enquiries and quote requests submitted through our website or by contacting us.
   

Processing based on consent or our legitimate interests

• Email marketing and updates.

• Website analytics and performance measurement.

We do not routinely process special categories of personal data.

5) What is our legal basis for processing your personal data?
a) Personal data (Article 6 of the UK GDPR)
Our lawful bases for processing your general personal data are:

• Article 6(1)(b) — Contract: processing necessary to take steps at your request prior to entering into a contract, for example where you ask us for a quote.

• Article 6(1)(a) — Consent: where you have agreed to receive marketing communications, and for non-essential cookies. You can withdraw consent at any time.

• Article 6(1)(f) — Legitimate interests: for responding to general enquiries, following up with you, analysing website usage, improving our service, and keeping our website secure. Where we rely on legitimate interests, we balance these against your rights and freedoms.

Where we send marketing to people who have previously enquired about similar products, we may rely on the "soft opt-in" under the Privacy and Electronic Communications Regulations (PECR). You can opt out of any marketing at any time.

6) Sharing your personal data
Your personal data is treated as strictly confidential and is shared only where necessary to run our website and respond to you. This may include:

• Our website hosting provider.

• Our email marketing provider.

• Our website analytics and advertising providers.

These third parties act as our processors. They may only use your data on our instructions and must keep it secure. We do not sell your personal data.

7) International transfers
Some of the providers we use to run our website, email, analytics and advertising may process data outside the UK, including in the United States. This applies to providers such as our website platform, email marketing tool, and analytics and advertising services.
Where data is transferred outside the UK, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision recognised by the UK Government.

8) How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary:

• Enquiry and quote data: we keep this until you ask us to delete it, or until it is no longer needed to manage your enquiry, whichever is sooner.

• Marketing data: until you withdraw consent or opt out, after which we will stop using it for marketing.

You can ask us to delete your data at any time using the contact details in this policy.

9) Cookies
Our website uses cookies and similar technologies to make the site work, to understand how it is used, and to support our advertising. Non-essential cookies, including analytics and advertising cookies, are only set with your consent through our cookie banner. Full details of the cookies we use are set out in our separate Cookie Policy.

10) Your rights and your personal data
Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data we hold about you.

• The right to request that we correct any personal data found to be inaccurate or out of date.

• The right to request that your personal data is erased where it is no longer necessary to retain it.

• The right to request that we provide you with your personal data and, where possible, transmit it directly to another data controller (the right to data portability), where applicable.

• The right, where there is a dispute about the accuracy or processing of your personal data, to request a restriction on further processing.

• The right to object to the processing of personal data, where applicable, including for direct marketing.

• The right to withdraw consent at any time where processing is based on consent.

11) Automated decision making
We do not use any form of automated decision making that produces legal or similarly significant effects.

12) Further processing
If we wish to use your personal data for a new purpose not covered by this notice, we will provide you with a new notice explaining the new use before processing begins, setting out the relevant purposes and processing conditions.

13) Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.

14) How to make a complaint
To exercise any of your rights, or to raise a query or complaint, please contact our Data Protection Officer, Trevor Gray, at trevor.gray@sandhurstautoprint.co.uk in the first instance.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner's Office on 0303 123 1113, via https://ico.org.uk/global/contact-us/email/, or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

MOGO is a brand operated by New Auto Ltd (Registered in England No. 03051444). Registered office: Unit 9 Springlakes Estate, Deadbrook Lane, Aldershot, Hampshire, GU12 4UH.