PRIVACY POLICY

Inchcape Mobility Limited

Notice relating to the Personal Data (Privacy) Ordinance
We, Inchcape Mobility Limited (“IML”) are committed to protecting your personal and data privacy. This Privacy Policy is intended to explain our privacy practices.

By providing your Personal Data to us, you are consenting to this Privacy Policy and to the collection, use, access, transfer, storage and processing of your personal information as described in this Policy.
 
Collection of Personal Data
“Personal data” refers to any data which directly or indirectly identifies you as an individual. We collect and use personal data that we believe to be relevant and necessary to conduct our business with you. The types of personal data we collect may include, but not limited to:

• - Contact information such as your name, email address, mailing address, telephone number, and fax number;
• - Unique identifiers such as your HKID and passport number; and
• - Billing information such as your credit card number, bank account information, and billing address.

[If you choose not to provide your personal data to us, you will in most cases still be able to use most of this site. However, we may not be able to provide you with all of our products or services or access to certain parts of the site which require registration if any.]
 
Use of Personal Data
Your personal data may be used for the following purposes:-

• (a) purchase of our products/services,
• (b) processing your application for and providing vehicle insurance and/or financing or leasing of vehicles;
• (c) arranging for the maintenance, repair and other after-sale services of vehicles;
• (d) assessment, maintenance and improvement of our services;
• (e) providing you with customer service and responding to your queries, feedback or claims;
• (f) conducting market analysis, statistical or other surveys, research and studies;
• (g) marketing products and/or services of IML and/or its affiliates, subsidiaries or associated companies and all other incidental and associated purposes directly relating thereto. Please refer to the section “Direct Marketing” below for further information;
• (h) detecting, investigating and preventing activities that may be against the law; and
• (i) for compliance with any applicable laws and regulations.

 
Direct Marketing
We intend to use your personal data for direct marketing carried out by IML, and for such purposes your personal data held by IML may be provided to any of our affiliates, subsidiaries or associated companies for their use for direct marketing. The intended kinds of personal data to be used and the intended classes of marketing subjects are specified below. However, we may not so use or provide your personal data unless exempted by the Personal Data (Privacy) Ordinance (“the Ordinance”) or we have received your consent.
 
For the above direct marketing use, IML intends to use your name and contact information for the supply of our products and/or services which we may offer to you or you may require from us from time to time; and also for marketing, promotional and customer relationship management purposes, such as sending you updates on latest offers and promotions in connection with our products and services and conducting market research.
 
You can always opt-out free-of-charge by contacting our Customer Experience Division, Inchcape Mobility Limited at 11/F Tower B, Manulife Financial Centre, 223-231 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong or by email to unsubscribe@inchcape.com.hk if you no longer wish any of your personal data to be used in any of the described direct marketing purposes.
 
Disclosure of Personal Data
Personal data supplied to IML will be kept confidential. However, we may disclose such data to or such data may become accessible or known to the following persons or in the following circumstances:
 

• (a) our agents, service providers and consultants who process data on our behalf, provide maintenance services of our database or data entry services or who otherwise provide us with technical support;
• (b) our employees who need to know such data in order to process it for us or for the performance of their duties;
• (c) our affiliates, subsidiaries or associated companies for purposes mentioned above and all other incidental and associated purposes relating thereto for fulling the purposes for which it was collected (subject to any consent requirement relating to “Direct Marketing” above);
• (d) our professional advisers including financial advisers and legal advisers;
• (e) in cases where it is required by law or law enforcement agencies or a court order;
• (f) when we believe in good faith that disclosure is necessary to protect your safety or the safety of others or for the detection, investigation or prevention of illegal activities including fraud; or
• (g) as a result of a sale, merger, acquisition, consolidation, group reorganization, change of control, liquidation, or transfer of our assets.

 
Other disclosure of your personal data will only be undertaken after we have obtained your prescribed consent, or as may be required by law.
 
Storage of Personal Data
Due to the international nature of our business, we may process and store your personal data outside Hong Kong. We may therefore transfer your personal data to our affiliate, subsidiary or associated companies outside Hong Kong for data processing and storage. This may involve a transfer of your personal data to a jurisdiction where the level of personal data protection may be different.
 
Data Retention
Unless there is a specific legal requirement for us to keep the data, we will take all reasonably practicable steps to erase your personal data that is no longer required for the purposes for which the data was originally collected.
 
Commitment to Data Security
Security is our top priority. We take appropriate steps to ensure that your personal data will be protected. We use a variety of physical, technological and organizational measures to safeguard and secure your personal data from unauthorized or accidental access, processing, erasure or other use.
 
Please however note that no data transmission over the Internet can be guaranteed to be completely secure. As such, we do not guarantee the security of any data that you transmit to us or receive from us over this site.
 
Other Information Collected
We may collect anonymous information about how you have used this site by means of cookies. We may also collect anonymous information about the referring website (for example Google search) or the referring banner which leads you to this site. Such information collected does not personally identify you but may be helpful to us for marketing purposes or improving the services we provide.
 
Changes to the Privacy Policy
We will post on our website at www.imusedcar.com.hk any changes to our Privacy Policy, so that you will know from time to time updates to our Privacy Policy.
 
Access to and Correction of Personal Data
You are entitled to request access to personal data held by us about you and to correct such data. In accordance with the terms of the Ordinance, we may charge a reasonable fee for the processing of such data access or correction requests.
 
You may direct your request in writing to our Customers Experience Department, Inchcape Mobility Limited at 11/F Tower B, Manulife Financial Centre, 223-231 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong or by email to unsubscribe@inchcape.com.hk .