This privacy notice applies to you if you are external to our business and we process your personal information and you are not an officer, employee or worker of ours, or a prospective employee or worker of ours.  This privacy notice also applies if you are disclosing personal data to us which identifies third parties such as previous owners of salvaged goods sold via our website.

You may, for example be an individual that works at a supplier or customer of ours, an individual which has registered to use our website in capacity as a user, bidder, buyer or seller, a visitor to one of our work sites or any previous registered owners of the salvaged goods being sold via our website, a shareholder or investor in one of our companies, an individual whose activities are captured on a CCTV system that we operate or an individual who is affected by our activities or otherwise has a relationship with us.

Each seller of salvaged goods shall indemnify and keep indemnified HKR from any and all claims, causes of action, suits, damages or demands, arising out of that seller’s failure to comply with data privacy laws.

Please note that not all parts or the content of this privacy notice may relate to you, as this will depend on your relationship with us.  For example, aspects only relevant to a user of our website would not apply to you unless you visit or use our website, and provisions relating to CCTV would not apply to you unless you visit premises where we operate CCTV. However, some parts of this privacy notice will always apply to you, for example the section on your rights and how to make a complaint.

When we say, we, our or us in this privacy notice, we mean Hudson Kapel 101 Limited trading as HKR a private limited company incorporated in England and Wales. Registered Number: 13916564. Registered Office is at: Building 101 Thurleigh Airfield Business Park, Thurleigh, Bedfordshire, United Kingdom, MK44 2YP.

For the purposes of data protection, we will be the controller of your personal information. Being a controller of your personal information means that we are responsible for deciding how we hold and use your personal information.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We may collect the following types of personal information about you:

• Contact details: information that allows us to identify and contact you directly such as your personal or business name, addresses, email address, telephone number.
• Identification information: official identification details, drivers licence, VAT number information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes.
• Account information: such as your email address, username and password when you set up an account with us and trade references.
• Financial and payment information: including bank details, credit card or other payment details for the purpose of making refunds for our products and/or services or us making payment to you for your products and/or services.
• Vehicle registration number, VIN number, make and model: for example, if you are selling or buying a vehicle using our services or if you are driving to visit us at our premises, worksites or an event.
• Details of the correspondence (including e-mail correspondence) you send and receive from us: this includes letters and emails, correspondence via the website user account, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
• Tax or other government identifiers: such as your VAT number.
• Advisors appointed by you: including lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
• Business information: including transactions, business relationships and amounts paid or owed.
• Creditworthiness: we may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you or the organisation you work for.
• Details of your performance: when working with or for us or in relation to any project or work we are engaged in or when using our services.
• CCTV images: if you visit any of our premises which has areas covered by our CCTV system.
• Fraud prevention related information: this may include details of other transactions you have been involved in.
• Your usage of any IT systems we make available to visitors to our premises or properties we own: for example usage of our internet and Wi-Fi facilities.
• How you use our website: we collect information about the pages you look at and how you use them, entry and exit data when you look at or leave our website and details of products, services and materials that may be of interest to you, usernames and passwords and the devices used.
• IP address information: your computer's IP address allows us to track your usage of our website or applications.
• Your marketing preferences: so that we know whether and how we should contact you and what is most likely to interest you.
• Subscription information: for example, when you subscribe to one of our blogs, mailing lists or other materials.
• Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves, for example photos and videos of salvaged goods to be sold at auction or where a video conference is recorded.
• Any other personal information you provide to us.
  

We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your trade union memberships;
• information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
• biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also generally not collect, store and use any criminal records information in relation to you.  If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

We will collect personal information from a number of sources. These may include the following:

• Directly from you: for example, when you indicate that you may wish to make a bid, purchase or sale, when you complete and register your details to open a user account for use of our website and services, if you attend an auction, when you or our customers receive or use our products and/or services or use our website or provide information to us through our website or at one of our site locations[1], if you are involved in a supply relationship with us, complete forms we provide to you, use our website, make a complaint, provide money laundering information to us, contact us by phone, email or communicate with us directly in some other way or you enter an area covered by a CCTV system we operate.
• Our customers and suppliers (including contractors and subcontractors): for example, so that we can perform our contracts with them or in connection with the relationship between us.
• Our websites: this includes personal information collected automatically through our websites or other applications which provide us with information about how you use them and the devices that you use to connect to them.
• Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms.
• Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.
• Our professional advisors: such as lawyers, accountants, financial advisors, planning consultants, surveyors, consultants and other advisors.
• Law enforcement: such as the police, courts and security services.
• Relevant regulators: for example the Information Commissioner's Office or Companies House.
• The Government and local authorities: for example to assist with investigations, or in connection with applications e.g. involving HMRC, a local authority.

We will also collect additional personal information about you throughout the period of any relationship we have with you.

If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

The points below describe the main purposes for which we may process your personal information.  Which will apply will depend upon the nature of your relationship and interactions with us.

• Enter into and perform contracts: where we may be supplying products/services to you or an organisation you work for and/or you or an organisation you work for may be supplying products/services to us or we may be involved in similar arrangements with third parties.
• Manage our relationship with you or the organisation you work for: this will cover our day to day dealings with you or the organisation you work for.
• Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the organisation you work for: where either you or the organisation you work for raise such matters or we need to raise such matters with you or the organisation you work for.
• Maintain and improve our services and/or products: we are always looking to improve our services, products and business and we may use your personal information to help us achieve the levels of service we aspire to and to improve them.
• Carrying out identity and credit checks: this will be where we have a legal obligation to do so or we may enter into or are already in a trading relationship with you.
• Anti-money laundering checks: where we are legally obliged to carry out these checks on you, particularly where you are looking to or have invested in our business.
• Data analytics, statistical analysis and other research: this may be to help us better understand the users of our services, the markets in which we operate, our online services (e.g. our website).
• Security of our IT systems: where we provide IT related services to you (e.g. our website, wi-fi or internet access) then we need to keep those systems safe and secure and may use your personal information to do this.
• Staff training: we may use some of your personal information as case studies or in training to help improve the quality of our staff.
• Direct marketing: we may use your personal information to send you marketing materials that may be of interest to you, generally this will only be where you are a potential or actual investor in our funds and generally only where we have your consent to do so.
• Holding events: we may hold events which you are invited to attend, and in these cases we may process your personal information so that you can attend and to.
• To comply with our legal and regulatory obligations: we may have legal obligations to use your personal information in a particular way, e.g. a HMRC investigation or to account for and pay VAT.
• To operate and manage our business and internal reporting: we will need to process your personal information in the operation and management of our business, which may include internal reporting, where it is relevant for us to do so.
• Storage of records relating to you and also records relating to our business: we like every business need to keep records, and this will include general business records and also records which are specific to any relationship we have with you.
• Operation and monitoring of our CCTV systems: if you visit any premises then they may have CCTV systems in and around them and they may therefore capture images of you.
• To prevent and detect criminal or improper acts (including CCTV): we have legal and regulatory obligations to make sure legal and regulatory requirements are upheld, and we may process relevant personal information about you in order to achieve this, and this will also include any personal information captured by any CCTV systems that we operate.
• Business continuity: we may keep duplicate backups, especially of electronic personal information, to protect us and allow quicker recovery from any issues which may threaten our business continuity.

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.  We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.

We may anonymise and aggregate any of the personal information we hold about you (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

We will only use your personal information when the law allows us to.  This means we must have one or more legal bases to use your personal information.  Most of these will be self-explanatory.  The most common legal bases which will apply to our use of your personal information are set out below:

• Where we need to perform the contract we have entered into with you or the organisation you work for, which covers your relationship with us or to take steps to enter into that contract. This will apply to you if you are an investor with us, a buyer or a supplier to us.
• Where we need to comply with a legal obligation which applies to us, for example complying with health and safety laws for visitors, money laundering laws, financial regulation that applies to our activities.
• Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.This for example would cover use of your personal information if you work for a supplier of ours, and we need to use your details to contact the supplier you work for.Legitimate interests also covers most CCTV systems as it is a legitimate interest to protect against crime and other misconduct.It is also a legitimate interest to carry out marketing activities, though we generally ask for your permission before we send you any marketing materials.
• Where you have given your consent. Generally, we do not rely on or need your consent for almost all uses we make of your personal information.
• Where we are processing any sensitive special category personal information about you (which covers personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation) then we also need to have one or more of the following legal bases for using your personal information.
• Where we have your explicit consent to do so.
• Where it is necessary for us to comply with our obligations and exercising our rights in the field of employment law, social security law and social protection law.
• Where we need to protect your vital interests (or someone else's vital interests).
• Where you have already made public the personal information.
• In establishing, exercising or defending legal claims, whether those claims are against us or by us.
• Where it is necessary in the public interest.

We will not usually process any of these types of special category personal information about you, and in any cases where we do process special category personal information about you it will generally be to comply with legal obligations, where you have given your consent or in establishing, exercising or defending legal claims.  In some cases more than one legal bases may apply to our use of your personal information.

In the event we process criminal records information about you, then we will either do so either to comply with our legal obligations or with your consent.

We may share your personal information with the following third parties:

• Advisors appointed by you: for example any financial advisors, lawyers, surveyors or other professional advisors appointed by you or acting for you.
• Anyone you ask us to pass your information to: for example they might be relatives of yours or people you have given authority to so they can act on your behalf.
• Other companies that we outsource to: third parties that process personal information on our behalf and in accordance with our instructions for example in relation to management of collection of funds. Our legal and other professional advisers, including our auditors or any professional advisors appointed by you, for example a legal advisor.
• Other companies in our supply chain: for example, so that they can contact you about any issues in the supply chain or where your personal information is relevant to a sub-contractor or party above us in the supply chain.
• Other uses of our services: for example, general users of our website and those participating in the auction services as buyers, bidders and sellers.
• Credit reference and other identification agencies: for example, so that we can assess your creditworthiness and to verify your identity.
• Third parties who ask for or want referrals: for example we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
• Marketing and public relations companies: for example to help us to develop, carry out and assess marketing and PR campaigns.
• Other service providers and advisors to us: for example such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent or who may operate a CCTV system on our behalf.
• Information providers: which may include credit reference agencies, money laundering check providers, Companies House, the Land Registry.
• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business or parts of our business.
• Relevant regulators: for example the Information Commissioner's Office, or Companies House.
• The Government and local authorities: where we are required to do so by law, for example HMRC, or to assist with investigations, for example the Financial Conduct Authority.
• Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime, the protection of national security and if we receive any parking notices after your purchase of a vehicle, to settle such notices.
• Insurers and insurance brokers.

Also see our separate cookie policy at for more details about how we use cookies on our website.

We may provide third parties with aggregate statistical information and analytics about users of our products and services so they can produce reports, but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally permitted to do so.  We do not sell, rent or trade your data.

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Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS/MMS or via targeted marketing delivered online through social media and other platforms with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or products from us previously.

The personal information we collect may be transferred to and stored in countries outside of the UK and the EEA. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your personal information on our behalf we will put in place appropriate safeguards as required under data protection laws.  For further details please contact us by using the details set out in the “Contacting us” section below.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim.

We have set out below the main retention periods which will apply:

• For individual contacts at customers and suppliers this will be for as long as we have a contract or relationship with that customer or supplier and then generally for a period of 7 years afterwards.
• For other persons whose personal information is processed as part of the provision of our products and/or services to our customers, it will generally be a period of 7 years after our relationship with the relevant customer ends.
• For website users it will generally be a period of 7 years after you used our website.
• For individuals whose images are captured on a CCTV system operated by us it will generally be up to 30 days (after that time the recording media is generally overwritten) unless a request for access to the relevant CCTV images has been made to us during that period, in which case the relevant CCTV images will be retained for as long as they remain relevant.In the case of investigations, e.g. a criminal prosecution, that may be many years.

Whichever time period applies, we do not guarantee to retain your personal information for the whole of the periods set out above; they are usually the maximum period, and in some cases, we may keep your personal information for a much shorter period.

However, where any personal information becomes relevant to legal proceedings or an investigation, then it may be retained for longer periods than those set out above and retained for as long as it remains relevant to the legal proceedings or investigation.

To the extent that we act as a processor, we will only process personal information required to be processed pursuant to that role for as long as is necessary in order for us to carry out our duties and obligations as a processor.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section below.

We have numerous security measures in place to protect the loss, misuse and alteration of personal information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures will protect your personal information, however we do take all reasonable measures to protect your personal information. We do take data security very seriously and will use all reasonable endeavours to protect the integrity and security of any personal information we collect about you.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those of our staff, agents, contractors and other third parties working on our behalf who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

You have the following rights in relation to your personal information:

• The right to withdraw any consent you have given to us in relation to our use of your personal information;
• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to object to us sending you direct marketing materials;
• the right to request that we transfer elements of your personal information either to you or another service provider in certain circumstances; and
• the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your personal information to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal information.  However, some of your rights have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is an appropriate security measure to ensure that personal information is not disclosed to any person or influenced by any person who has no right to do so.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s Office website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. For complaints to the Information Commissioner’s Office then please see https://ico.org.uk/make-a-complaint/. However we are here to help and encourage you to contact us to resolve your complaint first.

Deleting your HKR account data

You may request that we delete your account data, erasing your account details and history. You can exercise your right to delete your HKR web and mobile app account data by submitting a request with our team by emailing admin@hkr.co.uk.

Account Deletion via mobile app.

To permanently remove your HKR account and all data across both web and mobile app:

• Sign into the HKR mobile app.
• Navigate to your Profile in the app navigation bar.
• Select Details.
• Select Delete Account.
• Confirm (following this you will be logged out of your account).

This action ensures all your account data, including personal data and vehicle history will be removed in accordance with our Privacy Policy.

Please note that this action will also remove your account access on the HKR web app - this data cannot be recovered and you will be unable to access your account after confirming account deletion.

Please also note that uninstalling or deleting the HKR app will not delete your account information, to action this you should follow the steps given above.

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this notice and therefore, please check this page occasionally to ensure that you’re happy with any changes. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

In the event of any query or complaint in connection with the information we hold about you or in connection with this notice, please email our Data Protection Compliance Manager at Matt.Breeze@Reemaq.com or write to us at Attention of the Data Protection Officer, Building 101 Thurleigh Airfield Business Park, Thurleigh, Bedfordshire, United Kingdom, MK44 2YP.

This notice was last updated on 10/05/2024.