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NMLT-Policy

Privacy Statement

  1. Nwaguatahihia Motors LTD (Vehicle Delivery Service) Ltd (“we”, “us”, “our” below) is committed to protecting your privacy and maintaining the security of any personal information received from you, and is the controller and responsible for your personal data. We strictly adhere to the requirements of data protection legislation in the USA.
  2. The purpose of this statement is to explain to you what personal information we collect and how we may use it. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
  3. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
  4. When you access the application we may ask you for your details (Personal data). Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. • Contact Data includes billing address, delivery address, email address and telephone numbers. • Transaction Data includes details about services you have purchased and related items. • Usage Data includes information about how you use our website and services. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice. We do not collect any 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). If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with or relating to you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. 5. We use your personal information in connection with the operation of our business and for no other purpose. We will only use your personal data when the law allows us to. Most commonly, we will use and share your personal data in the following circumstances: • Where we need to perform a contract we are about to enter into or have entered into with you or a contract relating to the provision of vehicles or other services to you. Specifically, if we or our sub-contractors deliver a vehicle to you we will securely store the personal data which we hold about you, and share it with our sub-contractors (but with no-one else, and for no other purpose than in relation to the delivery of your vehicle, unless required or allowed by law or regulation). • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data. 6. We do not sell, rent or exchange your personal information with any third party for commercial reasons. We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer/deliveree of vehicles, and other items (a) Identity

(b) Contact Performance of a contract

To process and deliver your order (a) Identity

(b) Contact

(c) Transaction (a) Performance of a contract (including sub-contracts into which we enter)

(b) Necessary for our legitimate interests

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity

(b) Contact

(c) Profile (a) Performance of a contract

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical (a) Necessary for our 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)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 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 get 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. 7. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 6 above. • Internal Third Parties • External Third Parties • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 8. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, taxation, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers. 9. We follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorized access in accordance with the UK data protection legislation. We do not collect sensitive information about you except when you specifically knowingly provide it. 10. If you have any questions about privacy or wish to seek to exercise your legal rights (mentioned below) please contact us at: Nwaguatahihia Motors (Vehicle Delivery Service) Ltd.

  1. Your Legal Rights You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 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. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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. Object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. 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. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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