1. Who We Are
Hub 33 ("we", "us", "our") is the data controller responsible for your personal data. We operate a car buying service across Scotland and England, accessible at hub33.co.uk.
2. Information We Collect
We collect and process the following categories of personal data:
- Name — provided when you submit an enquiry, used to identify you and personalise our communications
- Email address — provided when you submit an enquiry, used to send your valuation and follow-up correspondence
- Phone number — provided when you submit an enquiry, used to contact you regarding your vehicle sale
- Vehicle information — including registration number, make, colour, year, fuel type, mileage, condition, and any photos you upload
- Location — to facilitate vehicle collection
- Website usage data — including pages visited, browser type, device information, and IP address, collected automatically via cookies and analytics tools
3. How We Use Your Information
We use your personal data for the following purposes:
- To provide and manage our car buying services
- To contact you with a valuation and to discuss the sale of your vehicle
- To arrange vehicle collection where agreed
- To improve our website and services through usage analytics
- To comply with our legal and regulatory obligations
- To respond to your enquiries or complaints
We will not use your personal data for automated decision-making or profiling.
4. Legal Basis for Processing (UK GDPR)
We process your personal data under the following legal bases as defined by the UK General Data Protection Regulation (UK GDPR):
- Contract (Article 6(1)(b)) — processing is necessary to take steps at your request prior to entering into a contract, and to perform any contract we enter into with you
- Legitimate interests (Article 6(1)(f)) — we have a legitimate interest in improving our services and communicating with you about your enquiry, where this does not override your rights and interests
- Legal obligation (Article 6(1)(c)) — where processing is required to comply with a legal obligation
5. Data Sharing
We do not sell, rent, or trade your personal data to any third parties for marketing purposes.
We may share your data only in the following limited circumstances:
- Service providers — third-party companies that help us operate our website and services (e.g. hosting providers, email delivery services), who are contractually obligated to keep your data secure and use it only as instructed
- Legal requirements — where we are required to disclose data by law, court order, or governmental authority
- Business transfer — in the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Enquiry data (name, email, phone, vehicle details) — retained for up to 2 years from the date of your enquiry, or until the matter is fully resolved
- Completed transaction records — retained for up to 6 years in accordance with UK tax and financial regulations
- Website usage data — retained for up to 26 months in line with standard analytics practices
After these periods, your data will be securely deleted or anonymised.
7. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right of access — you may request a copy of the personal data we hold about you
- Right to rectification — you may ask us to correct inaccurate or incomplete data
- Right to erasure — you may request that we delete your personal data in certain circumstances
- Right to data portability — you may request your data in a structured, machine-readable format
- Right to object — you may object to processing based on legitimate interests
- Right to restrict processing — you may ask us to limit how we use your data in certain circumstances
To exercise any of these rights, please contact us using the details in Section 11. We will respond within one calendar month of receiving your request.
8. Cookies
Our website uses cookies — small text files placed on your device — to improve your experience. We use:
- Essential cookies — required for the website to function correctly
- Analytics cookies — to understand how visitors interact with our website (e.g. Google Analytics)
- Advertising cookies — to measure the effectiveness of our advertising campaigns (e.g. Google Ads)
You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of our website.
9. Data Security
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These measures include secure HTTPS connections, encrypted data storage, and restricted access to personal data.
However, no method of transmission over the internet is completely secure. While we strive to protect your data, we cannot guarantee absolute security.
10. ICO and Complaints
If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent data protection authority.
We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us first using the details below.
11. Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or your personal data: