Privacy Policy

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Effective Date: 08/05/2025

At The Classic & Specialist Car Broker Ltd ("we", "us", or "our"), we are committed to protecting your privacy and handling your personal data in full compliance with the UK GDPR, EU GDPR, California Consumer Privacy Act (CCPA), and all other applicable data protection legislation.

By using our website (www.theclassicandspecialistcarbroker.com) or our services, you agree to the terms of this Privacy Policy.

1. What We Collect

We may collect the following categories of personal data:

• Contact Details: Name, email address, phone number, postal address, and company name
• Transaction Information: Vehicle details, preferences, financial and payment data
• Identity Verification Data: Documentation and information collected as part of our Anti-Money Laundering (AML) and Know Your Client (KYC) obligations, including proof of identity and proof of address where required
• Technical Data: IP address, browser type, operating system, and cookie identifiers
• Usage Data: Site activity, search terms, pages visited, and interaction logs
• 
  

We collect only what is necessary to deliver, manage, and improve our services.

Note: Beyond our standard AML/KYC requirements, we do not intentionally collect sensitive personal data (such as national ID numbers or driver's licence details) for any other purpose. Where such data is required outside of AML/KYC compliance, we will request it separately with your explicit consent.

2. How We Use Your Data

Your personal data is used for the following purposes:

• To process transactions and vehicle brokerage contracts
• To fulfil our legal obligations under Anti-Money Laundering (AML) regulations and to conduct Know Your Client (KYC) checks prior to entering into any transaction
• To provide customer support and respond to enquiries
• To send service updates, offers, or marketing communications (with your consent)
• To comply with legal, tax, or regulatory obligations
• To improve our website and services based on usage trends and feedback

3. Legal Basis for Processing

We rely on the following legal bases to process your data:

• Consent – e.g., when you sign up for marketing communications
• Contractual Necessity – e.g., processing vehicle sales or purchases
• Legal Obligation – e.g., tax and accounting requirements, AML/KYC compliance under the Proceeds of Crime Act 2002, the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, and any other applicable legislation
• Legitimate Interests – e.g., fraud prevention, analytics, and service optimisation

4. Sharing Your Information

We do not sell or rent your personal data.

We may share it with trusted third parties, such as:

• Payment processors, logistics providers, and IT service vendors
• Legal authorities, if legally required or to protect our rights
• Business successors in the case of a merger, acquisition, or sale of assets
• Regulatory bodies and law enforcement agencies where we are required to report under AML legislation

Third-Party AML & KYC Requirements

All third parties with whom we share data or enter into a business relationship are required to satisfy our Anti-Money Laundering (AML) and Know Your Client (KYC) standards as a condition of engagement. This means:

• Every third party must demonstrate compliance with applicable AML legislation and regulations relevant to their jurisdiction before we will share data or conduct business with them
• Third parties are required to maintain and evidence adequate KYC procedures, including the verification of the identity of their own clients and counterparties where relevant
• We will not engage with, refer business to, or share personal data with any third party that cannot satisfy our AML and KYC requirements or that we have reasonable grounds to suspect is operating outside of applicable financial crime legislation
• Our internal Third-Party Due Diligence Policy governs the onboarding, monitoring, and review of all third-party relationships, incorporating AML/KYC assessments as a mandatory component

All third parties operate under strict data protection agreements and are contractually bound to meet our high ethical, legal, and security standards.

5. International Data Transfers

If we transfer your data outside the UK or European Economic Area (EEA) — for example, via cloud storage or email service providers — we ensure it is protected using:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Addendum
• Adequacy decisions from the UK or EU, where applicable

Where international transfers involve AML or KYC data, additional safeguards are applied to ensure compliance with the relevant financial crime regulations in all jurisdictions involved.

6. Data Retention

We retain your personal data only for as long as necessary to:

• Fulfil the purposes described in this policy
• Comply with legal, tax, or accounting requirements
• Meet our obligations under AML legislation, which may require retention of identity verification records for a minimum of five years following the end of a business relationship or transaction
• Resolve disputes or enforce agreements

Example timeframes:

• Transaction records: up to 7 years (for legal compliance)
• AML/KYC records: minimum 5 years from the end of the business relationship, in accordance with the Money Laundering Regulations 2017
• Marketing preferences: until consent is withdrawn
• Enquiries: up to 12 months after last contact

After the applicable retention period, your data is securely deleted or anonymised.

7. Your Rights

Depending on your location, you may have the right to:

• Access or request a copy of your personal data
• Correct or update inaccurate data
• Delete your data ("right to be forgotten")
• Restrict or object to certain types of processing
• Request data portability
• Withdraw consent at any time (e.g., for marketing emails)

Please note: Certain data, particularly that held in connection with our AML and KYC obligations, may be exempt from some of the above rights where retention or processing is required by law. We will advise you accordingly if this applies to your request.

To exercise your rights, please contact us at:
📧 enquiry@theclassicandspecialistcarbroker.com

You may be asked to verify your identity before we process your request.

If you are located in the UK and believe your data has not been handled in accordance with data protection laws, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: www.ico.org.uk
• Helpline: 0303 123 1113

We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO, so please feel free to reach out to us first.

8. Cookies

We use cookies and similar technologies to:

• Ensure site functionality and security
• Analyse website performance and visitor behaviour
• Personalise content and marketing (only with your consent)

You can manage your cookie preferences through your browser settings or via our cookie banner when you visit the site. For further information, please refer to our Cookie Policy.

9. Data Security

We implement industry-standard security measures to protect your data, including:

• SSL/TLS encryption
• Secure server infrastructure
• Access controls and authentication protocols
• Restricted access to AML/KYC records, limited to authorised personnel only

While we take all reasonable precautions, no system is entirely immune to risk. Please contact us immediately if you suspect any unauthorised use of your data.

10. Children's Privacy

Our website and services are not intended for individuals under 16 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.

11. Policy Updates

We may update this Privacy Policy from time to time. Updates will be posted on this page with the revised effective date. For significant changes, we may notify you via email or a prominent notice on our website.

12. Contact Us

The Classic & Specialist Car Broker Ltd
📧 Email: enquiry@theclassicandspecialistcarbroker.com
📍 Address: [Insert company's registered office or business address]

If you have any questions or concerns about this policy or how we handle your data, please do not hesitate to get in touch.

13. Governing Law and Unjustified Enrichment

This Privacy Policy and any disputes arising from it are governed by and construed in accordance with the laws of Scotland.

We operate under the principle that no party should receive unjustified enrichment at the expense of another. Any attempts to gain unfair advantage or benefits contrary to this principle will be dealt with strictly in accordance with applicable Scottish law.

Please note that we do not recognise or apply any religious laws, including Sharia law, in our business practices, data handling, or dispute resolution processes. All matters are handled strictly under applicable Scottish and UK laws.