DATA PROTECTION

PRIVACY POLICY 

for the Manheim Express platform 

Who are we? 

Cox Automotive Remarketing GmbH (the legal name for Manheim Express), Bubenheimer Bann 11, 56070 Koblenz 

You can reach our data protection officer, JURANDO GmbH, by datenschutz@pkwnow.de or by post at our address with the addition “Data Protection Officer”. 

We collect personal information about you when you sign up for and use our products and services, as well as when you use our website and platform. The types of personal information that we collect and use are listed below: 

a.) Visiting our website 

When you visit our website for informational purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to us. These are: 

• IP address 

• Date and time of the request 

• Time zone difference to Greenwich Mean Time (GMT) 

• Content of the request (concrete page) 

• Access Status/HTTP Status Code 

• amount of data transferred in each case 

• Website from which the request comes 

• Browser 

• Operating system and its interface 

• Language and version of the browser software. 

• We also store this data, including the IP address, in log files. 

 
This data is technically necessary for us to display our website, to ensure stability and security and to optimize our offer. 

The legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR, whereby our legitimate interest arises from the aforementioned purposes. 

We delete this data after 7 days at the latest. Any further storage only takes place after the IP address has been deleted or anonymized. 

b.) Cookies 

We use cookies on our site. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which certain information flows to us. 

We use transient and persistent cookies on our website. Transient cookies are automatically deleted when you close the browser. These include, in particular, session cookies. These store a so-called session ID, which can be used to assign various requests from your browser to the common session. This allows your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser. Persistent cookies are automatically deleted after a specified period of time, which may differ depending on the cookie. You can delete cookies at any time in the security settings of your browser. 

You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. We would like to point out that in this case you may not be able to use all the functions of this website. 

We also use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit. 

The use of cookies serves to make the use of our offer more pleasant for you and to optimize the user-friendliness. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you. These cookies allow us to automatically recognise that you have already been to us when you visit our site again. These cookies are automatically deleted after a defined period of time. 

When you visit our website, we draw your attention to the use of cookies by means of a cookie notice that refers to this privacy policy. There you can also consent to the use of cookies. 

The legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR, whereby our legitimate interest arises from the aforementioned purposes. If you consent to the use of cookies, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR. 

c.) Newsletter 

If you give us your consent, you can subscribe to our newsletter. 

To subscribe to our newsletter, we use the so-called double opt-in procedure. This means that after you have registered, we will send you an e-mail to the e-mail address provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your data will be automatically deleted. In addition, we store your IP addresses and times of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data. 

The only mandatory information for subscribing to the newsletter is your e-mail address. After your confirmation, we will store your e-mail address for the purpose of sending the newsletter. 

The legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR, as you have consented. 

You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare your revocation by clicking on the link provided in each newsletter e-mail or by e-mail to newsletter@pkwnow.de. After unsubscribing, we will delete your data immediately. 

d) E-mail contact

If you contact us via the e-mail addresses we provide, we will store the personal data you provide in order to answer your inquiries. 

The legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR, whereby our legitimate interest arises from the aforementioned purposes. If the contact is aimed at concluding a contract, if the contact is made within the framework of an existing contractual relationship, the legal basis is Art. 6 para. 1 sentence 1 lit. b GDPR. 

The data will be deleted when the request has been finally processed and there are no legal retention obligations. In addition, you can object to the processing at any time. 

e) Use of our Platform

If you want to use our platform, you must provide your personal data that is necessary for the execution of the user relationship in order to conclude the contract. Necessary mandatory information is marked as such, the other information is voluntary. We process the data you provide for the purpose of executing the user relationship. In doing so, we may also pass on your data to our payment service provider. 

The legal basis is Art. 6 para. 1 sentence 1 lit. b GDPR. 

We also process your data to inform you about other interesting products from our range. 

Due to commercial and tax law requirements, we are obliged to store your address, payment and order data for a period of ten years. However, two years after the end of the user relationship, we will restrict the processing, i.e.? h. Your data will only be used to comply with legal obligations. 

The entire process is SSL-protected to prevent unauthorized access by third parties. 

f) Social media plug-ins

We currently use the following social media plug-ins: Facebook, Instagram, Xing, and Twitter. We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the providers of the plug-ins. You can recognize the provider of the plug-in by the mark on the box by its first letter or logo. We give you the opportunity to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it, the plug-in provider will receive the information that you have called up the corresponding website of our online offer. In addition, the data referred to in a) of this declaration will be transmitted. In the case of Facebook and Xing, according to the respective providers in Germany, the IP address is anonymized immediately after collection. By activating the plug-in, your personal data is transmitted to the respective plug-in provider and stored there (in the case of providers in the Unites States of America (USA)). Since the plug-in provider collects data in particular via cookies, we recommend that you delete all cookies via the security settings of your browser before clicking on the greyed out box. 

We have no influence on the data collected and data processing processes, nor are we aware of the full scope of the data collection, the purposes of the processing, the storage periods. We also have no information on the deletion of the collected data by the plug-in provider. 

The plug-in provider stores the data collected about you as usage profiles and uses them for the purposes of advertising, market research and/or needs-based design of its website. Such an evaluation is carried out in particular (also for users who are not logged in) for the purpose of displaying needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this. Through the plug-ins, we offer you the opportunity to interact with the social networks and other users, so that we can improve our offer and make it more interesting for you as a user. 

The legal basis for the use of the plug-ins is Art. 6 para. 1 sentence 1 lit. f GDPR, whereby our legitimate interest arises from marketing purposes. If consent is given by clicking on a plug-in, the legal basis is Art. 6 para. 1 lit. a GDPR. 

The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in to the Plug-in Provider, the data you collect with us will be directly assigned to your existing account with the Plug-in Provider. If you press the activated button and e.g.? link to the site, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, but especially before activating the button, as this will prevent you from being assigned to your profile with the plug-in provider. 

Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers. There you will also find further information about your rights in this regard and setting options to protect your privacy. 

g) Google Web Fonts

This site uses so-called web fonts, which are provided by Google, for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly. For this purpose, the browser you use must connect to Google’s servers. This makes Google aware that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. If your browser does not support Web Fonts, a default font will be used by your computer. For more information about Google Web Fonts, see https://developers.google.com/fonts/ 

h) Google Maps

This site uses the Google Maps map service via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. In order to use the functions of Google Maps, it is necessary to store your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. The use of Google Maps is in the interest of an appealing presentation of our online offers and to make it easy to find the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. More information on the handling of user data can be found in Google’s privacy policy: 
https://www.google.de/intl/de/policies/privacy/ 

i.) Vimeo Videos

We integrate videos from the platform “Vimeo”. The provider is Vimeo.com Inc., 555 West 18th Street, New York, New York 10011, USA. The data collected when visiting our website is transmitted to the provider. In particular, the transmission of the IP address is necessary for the provider to be able to transmit the content. 

The legal basis for embedding the Vimeo videos is your consent and thus Art. 6 para. 1 lit. a GDPR. Vimeo.com Inc. has certified itself according to the EU-US Data Privacy Framework, so that a possible third-country transfer to the USA is justified by the corresponding adequacy decision of the EU Commission. We have also entered into the current EU Standard Contractual Clauses with Vimeo.com Inc. as a legal basis for any third-country transfer that may take place. After all, we assume that your consent also applies to the third-country transfer. In this regard, we would like to point out that we do not know exactly how the data is processed by Vimeo.com Inc. and who (e.g. US authorities and intelligence services) access the data. In general, there is no adequate level of data protection comparable to the GDPR in the USA and the enforcement of your rights can be considerably more difficult, which is why risks cannot be completely ruled out. 

Who your personal information may be disclosed to 

Your personal information will be shared with the following recipients:We will or may pass your personal information on to the following recipients: 

• Employees and contractors of Manheim Express. 

• Other members of the Cox Automotive Europe & UK Group. 

• Cox Automotive Brazil. 

• Third Party Suppliers operating on our behalf where necessary to provide you with the appropriate services. 

• Law enforcement agencies, Regulators and other investigative bodies where necessary for the prevention, detection or investigation of criminal or as required by law or otherwise to enable them to effectively carry out their functions. 

• We may transfer, sell or assign any of the personal information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business (or any part of our group). 

• We will disclose your information to a party involved in the sale of a vehicle in the event of a dispute relating to that sale. 

 
International transfers of personal information 

We transfer your information outside of the EU. We transfer your personal information to the countries listed below using the associated safeguards: 

• We transfer your personal data to our parent company Cox Automotive Inc (CAI) in the USA for the purposes of managing, administering and securing our products, platforms and systems. Where making such transfers, we do so using Standard Contractual Clauses (SCCs) as our chosen lawful safeguard. 

• We transfer your data to suppliers that are based outside of the EU for the purpose of fulfilling our obligations as outlined in the T&Cs. In such circumstances we will enter into a written agreement with the supplier which reflects the requirements of the applicable Data Protection Legislation and ensure that the appropriate lawful safeguard is in place. 
   

Your rights in relation to your personal informationWhat rights do you have? 

You have the right to:following rights in relation to your personal data: 

• Object to the processing of your personal data in certain circumstances 

• Object to the use of your personal information for direct marketing purposes 

• Request the deletion of your personal data in certain circumstances 

• Request access to the personal information we hold about you 

• Request that we rectify inaccurate personal information we hold about you 

• Restrict the way in which we can use your personal information in certain circumstances 

• Request the portability of your data in certain circumstances 

• You have the right, where personal information is processed on the basis of consent, to withdraw that consent at any time 

If you are unhappy with the way in which we have handled your personal information you have the right to lodge a complaint with via email to info@manheim-express.de. You can contact them at Cox Automotive Remarketing GmbH Bubenheimer Bann 11 56070 Koblenz or online at manheim-express.eu.

Retention and disposal of personal information 
 

We will retain your personal information for as long as we require it in order to provide you with the products and services you have requested. We will retain certain personal information beyond that point where it is necessary for compliance with a legal obligation we are subjected to or where we have a legitimate business reason to do so. 

Automated decision making 

 
We do not undertake any automated decision making using personal information we collect about you.