Privacy policy

MOGO Privacy Policy (Online Store)

Introduction

We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you use our online store. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on the processing of personal data are set out in the UK General Data Protection Regulation (the "UK GDPR") and the Data Protection Act 2018.

1) Definitions

Data controller — A controller determines the purposes and means of processing personal data.

Data processor — A processor is responsible for processing personal data on behalf of a controller.

Data subject — A natural person.

Categories of data — Personal data and special categories of personal data.

Personal data — Any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier. For example, name, home address, email address or telephone number. Online identifiers include IP addresses and cookies.

Special categories of personal data — Sensitive personal data, including genetic and biometric data processed to uniquely identify an individual, as well as racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, and religious or philosophical beliefs.

Processing — Any operation performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, alignment, restriction, erasure or destruction.

Third party — A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2) Who are we?

MOGO is a brand operated by New Auto Ltd.

New Auto Ltd is the data controller. This means we decide how your personal data is processed and for what purposes.

Our contact details are: New Auto Ltd, Unit 9 Springlakes Estate, Deadbrook Lane, Aldershot, Hampshire, GU12 4UH.

For all data matters, contact our Data Protection Officer, Trevor Gray, at trevor.gray@sandhurstautoprint.co.uk.

3) The purposes of processing your personal data

We use your personal data for the following purposes:

  • To process and fulfil your order, including taking payment and arranging delivery to your given address.
  • To create and manage your customer account, where you choose to register one.
  • To handle returns, refunds, guarantees and warranty claims.
  • To respond to your enquiries and provide customer support.
  • To send marketing communications where you have agreed to receive them, or where we are otherwise permitted to do so.
  • To understand how our store is used and to improve our products, service and online experience.
  • To protect our store, verify transactions and prevent fraud.

4) The categories of personal data concerned

With reference to the categories described in the definitions section, we process the following categories of your data:

Processing necessary for the performance of a contract, or to take steps prior to a contract

  • Fulfilment of online orders, including payment and delivery.
  • Account management.
  • Returns, refunds and warranty handling.

Processing necessary to comply with a legal obligation

  • Keeping records of transactions for tax and accounting purposes.

Processing based on consent or our legitimate interests

  • Email marketing and updates.
  • Website analytics and performance measurement.
  • Fraud prevention and store security.

We do not routinely process special categories of personal data.

5) What is our legal basis for processing your personal data?

a) Personal data (Article 6 of the UK GDPR)

Our lawful bases for processing your general personal data are:

  • Article 6(1)(b) — Contract: processing necessary for the performance of a contract to which you are party, or to take steps at your request prior to entering into a contract. This covers order fulfilment, payment, delivery, account management, and returns or warranty handling.
  • Article 6(1)(c) — Legal obligation: processing necessary to meet our legal duties, including keeping transaction records for tax and accounting purposes.
  • Article 6(1)(a) — Consent: where you have agreed to receive marketing communications, and for non-essential cookies. You can withdraw consent at any time.
  • Article 6(1)(f) — Legitimate interests: for providing customer support, analysing store usage, improving our service, verifying transactions and preventing fraud. Where we rely on legitimate interests, we balance these against your rights and freedoms.

Where we send marketing to existing customers about similar products, we may rely on the "soft opt-in" under the Privacy and Electronic Communications Regulations (PECR). You can opt out of any marketing at any time.

6) Sharing your personal data

Your personal data is treated as strictly confidential and is shared only where necessary to deliver our service. This may include:

  • Our ecommerce platform and hosting provider, which runs the online store.
  • Payment providers, to process your payment securely. We do not store full card details ourselves.
  • Our courier and delivery partners, to fulfil and deliver your order.
  • Our email marketing provider.
  • Our website analytics and advertising providers.

These third parties act as our processors, except where a payment provider acts as a controller in its own right for fraud prevention and regulatory purposes. Processors may only use your data on our instructions and must keep it secure. We do not sell your personal data.

7) International transfers

Some of the providers we use to run our store, payments, email, analytics and advertising may process data outside the UK, including in the United States. This applies to providers such as our ecommerce platform, email marketing tool, and analytics and advertising services.

Where data is transferred outside the UK, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision recognised by the UK Government.

8) How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary:

  • Order and transaction records: for a minimum of 6 years from the end of the relevant financial year, in order to meet our tax and accounting obligations and to cover guarantees and warranties.
  • Account data: for as long as your account remains active. If you close your account, we will delete or anonymise your data unless we are required to retain part of it for legal reasons.
  • Marketing data: until you withdraw consent or opt out, after which we will stop using it for marketing.
  • Enquiry and support data: until your query is resolved and for a reasonable period afterwards, or until you ask us to delete it.

9) Cookies

Our store uses cookies and similar technologies to make the site work, to keep your basket and checkout functioning, to understand how the store is used, and to support our advertising. Non-essential cookies, including analytics and advertising cookies, are only set with your consent through our cookie banner. Full details of the cookies we use are set out in our separate Cookie Policy.

10) Your rights and your personal data

Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data we hold about you.
  • The right to request that we correct any personal data found to be inaccurate or out of date.
  • The right to request that your personal data is erased where it is no longer necessary to retain it.
  • The right to request that we provide you with your personal data and, where possible, transmit it directly to another data controller (the right to data portability), where applicable.
  • The right, where there is a dispute about the accuracy or processing of your personal data, to request a restriction on further processing.
  • The right to object to the processing of personal data, where applicable, including for direct marketing.
  • The right to withdraw consent at any time where processing is based on consent.

11) Automated decision making

We do not use any form of automated decision making that produces legal or similarly significant effects. Our payment and checkout providers may carry out automated fraud screening as part of processing your transaction.

12) Further processing

If we wish to use your personal data for a new purpose not covered by this notice, we will provide you with a new notice explaining the new use before processing begins, setting out the relevant purposes and processing conditions.

13) Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.

14) How to make a complaint

To exercise any of your rights, or to raise a query or complaint, please contact our Data Protection Officer, Trevor Gray, at trevor.gray@sandhurstautoprint.co.uk in the first instance.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner's Office on 0303 123 1113, via https://ico.org.uk/global/contact-us/email/, or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

MOGO is a brand operated by New Auto Ltd (Registered in England No. 03051444). Registered office: Unit 9 Springlakes Estate, Deadbrook Lane, Aldershot, Hampshire, GU12 4UH.