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Privacy Policy – United Kingdom

Auto Grab UK Ltd

Company Number 15575378

275 New North Road, Islington Suite 1940, London, N1 7AA, United Kingdom

Amended: 10 November 2025

PRIVACY NOTICE

1. INTRODUCTION

1.1 Important information and who we are

Welcome to Auto Grab UK Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At Auto Grab UK Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom. This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data. The individuals from which we may gather and use data can include:

  • Customers
  • Suppliers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Auto Grab Holdings Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to support@autograb.com.au or by post to 275 New North Road, Islington Suite 1940, London, N1 7AA, United Kingdom.

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 with any complaints.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

  • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
  • Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
  • Transactional Data: This is information of details and records of all payments you have made for our services or products.
  • Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
  • Customer Support Data: This includes feedback and survey responses.
  • Usage Data: information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as market data on vehicle listing, prices and movements. We aggregate data and we do not intend to identify individuals through our use of aggregated data. 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 Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We may collect data in respect of the alleged commission of a criminal offence, to the extent this can be implied from the results of a public search regarding whether a vehicle has been reported stolen to the police.

Other than as specified above, we do not collect 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).

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

  • “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service. You have the right to revoke your consent at any time.
  • “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
  • “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
  • “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity Type of data Legal Justification Lawful basis for processing data
When a customer signs up as a user – Profile/Identity Data
– Contact Data
– Marketing and Communications Data
– Billing Data
– Transactional Data
– Technical Data
– Usage Data		 – Consent
– Contractual Obligations – we need to collect certain data to enter into a contract with you
– Legitimate Interest		 Consent
You will need to include Personal Data when filling in the Company profile on the Platform so the content you create is linked to your profile.
Contractual Obligation
In order to use our Platform, you need to contract with us under our Terms of Service and so this is necessary to form the contract between us. We need to retain your Transactional Data so that we can comply with our legal obligation to send you an invoice following a purchase.
Legitimate Interest
We need to know who you are so that we know who to deliver the service to once it has been purchased. It also enables us to provide support to the right individual in case there is an issue with the purchased product. We need to process billing data so that we know who and where to charge for the products you have purchased from us.
When you contact our customer service unit to make a complaint, provide feedback, submit an enquiry or request a call-back – Profile/Identity Data
– Contact Data		 Consent
Legitimate Interest		 Consent
We ask you for your name and contact details so that we can respond to your enquiry. You must volunteer this information. We will not extract it from you without your consent.
Legitimate Interest
We need to know who you are and how to contact you so that we can get in touch with you to respond to your query.
When a user or customer requests to receive news about exclusive offers, promotions, or events – Profile/Identity Data
– Contact Data
– Marketing and Communications Data		 Consent Consent
You will opt in to receive promotional material from us and will be asked to provide your name and contact information so we can add you to our mailing list and share this with you.
Searching public websites to collect publicly available information about vehicles and potential sellers in order to notify dealers/fleet operators – Profile/Identity Data
– Contact Data
– Vehicle Data (which can be linked to the authorised owner)		 Legitimate Interest Legitimate Interest
We collect this personal data to provide services to dealers or fleet operators so that they can contact sellers.
Receiving customer lists from dealers to match with publicly available data – Profile/Identity Data
– Contact Data
– Vehicle Data (which can be linked to the authorised owner)		 Legitimate Interest Legitimate Interest
We collect this personal data to provide services to dealers so that, for example, we can match their previous customers with a customer who is now advertising their vehicle online so that the dealer can then contact that customer.
To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data – Profile/Identity Data
– Contact Data
– Technical Data		 Legitimate Interest 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.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences – Technical Data
– Usage Data		 Legitimate Interest Legitimate Interest
To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy.
Searching public websites to collect publicly available information about vehicles to provide services to insurance companies concerning vehicle pricing and anti-fraud measures – Profile/Identity data
– Contact data
– Vehicle Data (which can be linked to an owner)		 Legitimate interest Legitimate interest
We collect this personal data to provide services to insurance companies – these companies are an important part of the vehicle trade ecosystem to ensure vehicles are fairly priced and fraudulent claims are identified. There is a public interest in ensuring that insurance companies have access to UpToDate and accurate data.

3.2 Marketing and content updates

If you have given your consent, you will receive marketing and new content communications from us. You have the right to withdraw this consent at any time. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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 ask for 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.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Right to be informed: You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
  • Right of access: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a “data subject access request”). See section 4.5 below for more details on how you can make a data subject access request.
  • Right to rectification: You have a right to 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.
  • Right to erasure: You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, 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.
  • Right to object: You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
    1. Where we are processing your personal data for direct marketing purposes.
    2. 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.
    3. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Right to restrict processing. You have the right to request the restriction or suppression of your personal data. Note that this is not an absolute right and it only applies in certain circumstances:
    1. If you want us to establish the data’s accuracy.
    2. Where our use of the data is unlawful but you do not want us to erase it.
    3. 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
    4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, 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.

If you wish to make a request under any of these rights, please contact us at support@autograb.com.au.

4.2 Your control over Auto Grab Holdings Limited’s use of your Personal Data

You may request your personal data be deleted at any time by requesting this in writing to your sales representative or by emailing support@autograb.com.au. We will process requests within 30 days and notify you once complete.

We do not guarantee the ability to delete all stored data. If you would like us to delete /correct personally identifiable data, let us know and we will action your request as soon as practicable.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing out after you have finished accessing your account.

4.3 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by using the unsubscribe link at the base of the email from us. Alternatively, you can contact your account rep or support@autograb.com.au.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

You may request your personal data by requesting this in writing to your sales representative or by emailing support@autograb.com.au. We will process requests within 30 days.

5. YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions. We will also share your Personal Data with our parent company Auto Grab Ltd who will use your Personal Data in accordance with the purposes set out in this Privacy Notice.

We may also share Personal Data with interested parties in the event that Auto Grab Holdings Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Auto Grab Holdings Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. 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 and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6. HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. INTERNATIONAL TRANSFER OF DATA

In using our Services, Personal Data may be transferred and processed in jurisdictions not officially recognized by the UK Government as providing an adequate level of protection (“Third Countries”). In cases where such transfers would be restricted under Data Protection Laws, we ensure compliance by implementing appropriate mechanisms. For transfers subject to EU regulations, we incorporate EU Standard Contractual Clauses (SCCs) with specific options detailed in our terms and conditions. Additionally, for transfers subject to UK laws, we incorporate a UK Addendum.

8. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated as at the date of amendment, shown above.

9. TERMS OF USE

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of the Auto Grab UK Ltd website. The terms governing the use of our products and services are contained in your customer contract with us. Please contact one of our sales representatives if you have any queries relating to our products and services.