Privacy Policy

1. About this Policy

This Privacy Policy explains how Second Gears Trading Ltd collects, uses, shares, and protects personal information when you use our website and services at secondgears.co.uk (the "Platform").

We have tried to write this in plain English. Where we use a technical or legal term, we explain what it means. If anything is unclear, email us at [email protected] and we will do our best to answer.

This Policy should be read alongside our Terms and Conditions.

2. Who we are

Second Gears Trading Ltd is the "data controller" for personal information processed through the Platform. That means we decide what personal information is collected and how it is used.

• Company number: 16327142
• Registered office: 11 Main Street, Barkby, Leicester, England, LE7 3QG
• Email: [email protected]

We are registered with the UK Information Commissioner's Office (ICO).

3. A plain-English summary

Before the detail, here is the short version of what we do with your data:

• If you're a seller: we collect your name, contact details, postcode, and vehicle information so we can publish your advertisement and pass on enquiries from buyers.
• If you're a buyer: we collect your name, business details, contact details, postcode, and payment information so we can manage your subscription and give you access to advertisements.
• We share seller contact details with buyers only where the seller has chosen to display them, or where the seller agrees to progress a specific enquiry.
• We send you emails (and sometimes WhatsApp messages) about your account, your listing, and information relevant to selling a vehicle or (for trade buyers) using our service. You can unsubscribe from any of these emails at any time.
• We use analytics and advertising tools (Google, Meta, TikTok) to understand and promote the Platform. You control these through our cookie banner.
• We never sell your personal information.

The rest of this Policy covers the detail.

4. What information we collect

4.1 Information you give us

When you register as a seller (by submitting a vehicle through our listing workflow):

• name
• email address
• phone number
• postcode
• account password

When you place an advertisement:

• vehicle registration, make, model, year, mileage, VIN, condition, damage details, MOT status, write-off category (if known), and other information you choose to provide
• photographs and any video you upload
• whether you want your phone number or WhatsApp displayed in the advertisement, or whether you prefer email-first contact

When you register as a trade buyer:

• name and business name
• business address and postcode
• VAT registration (if applicable)
• contact details (email and phone)
• payment information (processed by Stripe — see section 6)

When you contact us (by email, form, or message): the content of your communication and any attachments.

4.2 Information we collect automatically

When you use the Platform, we and our analytics and advertising partners collect:

• IP address, device type, browser, and operating system
• pages viewed, time spent, navigation paths, and referral source
• cookie identifiers and similar technologies

This is covered in section 9 on cookies.

4.3 Information from other sources

• Stripe provides us with confirmation that your payment has been received and limited transaction metadata. Full card details are handled by Stripe, not by us.
• Public registers (such as the DVLA's Vehicle Enquiry Service) may be used to cross-check vehicle information submitted in listings.
• If you contact us through a social media platform, that platform may share basic profile information with us in line with their own privacy policies.

5. How and why we use your information

We use your personal information for the following purposes and on the following legal bases under UK GDPR and the Privacy and Electronic Communications Regulations 2003 (PECR):

To provide the service you've asked for — legal basis: contract

• create and manage your account
• publish your advertisement
• pass enquiries and offers between sellers and buyers
• take subscription payment and manage billing (for trade buyers)
• send you transactional emails and WhatsApp messages — for example, confirmation that your listing is live, a new enquiry on your vehicle, a reminder that your listing is expiring, a payment receipt, or a password reset

To keep you informed about your listing and our service — legal basis: "soft opt-in" under PECR regulation 22(3), and our legitimate interest

When you register with us, you are using the Platform to sell your vehicle or (for trade buyers) to access vehicles for sale — in other words, you are engaging with us in negotiations for a sale. On that basis, we will also send you emails and (where available) WhatsApp messages about:

• activity on your listing and similar vehicles
• information relevant to selling your vehicle, such as guides, checklists, and tips
• success stories from other sellers
• platform updates, new features, and improvements
• for trade buyers: new listings that match your interests, changes to subscription tiers, and information relevant to using our service

Every such message includes a simple way to opt out — a one-click unsubscribe link in every email, or a "STOP" option in WhatsApp messages. If you opt out, we will stop sending you messages of this kind, although we will continue to send you essential transactional messages (such as enquiry notifications and billing).

If at any time we want to send you marketing that goes beyond the categories above — for example, promotional offers from unrelated partners or cross-sells to different services — we will either ask for your specific consent first or rely on another lawful basis.

To keep the Platform running safely and improve it — legal basis: legitimate interest

• protect against fraud, abuse, and unauthorised access
• monitor site performance and fix bugs
• analyse usage to improve features
• carry out internal reporting and business planning
• keep internal admin records of past advertisements (see retention in section 10)

To advertise the Platform to new users — legal basis: consent (via our cookie banner)

• use advertising cookies and pixels (Google, Meta, TikTok) to understand and measure the effectiveness of our campaigns and to reach new potential users

You can manage these choices at any time from the cookie preferences link in the site footer.

To comply with the law — legal basis: legal obligation

• keep financial and tax records
• respond to lawful requests from regulators, courts, the police, DVLA, HMRC, or other authorities
• investigate and report suspected fraud or stolen vehicles

6. Who we share your information with

We share personal information in the following circumstances.

6.1 Between buyers and sellers

• Where a seller has chosen to display their phone number or WhatsApp in an advertisement, any subscribing buyer can see it.
• Where a seller has chosen email-first contact, enquiries are passed on by email. The seller's further contact details are shared with a buyer only if the seller agrees to progress the enquiry.
• Where we operate close working arrangements with specific trade buyers, seller contact details may be made available directly to those buyers at the point of listing. This is disclosed in our Terms and Conditions.

Buyers and sellers must use each other's contact details only to discuss the specific vehicle and must not add them to marketing lists or share them with third parties (see our Terms).

6.2 Our service providers

We use carefully selected third parties to provide parts of the service. They process personal information on our behalf (as "processors") under written contracts that require them to keep it secure and use it only for the purposes we instruct. The main ones are:

We may change or add to this list over time. A current list is available on request from [email protected].

6.3 Authorities and other third parties

• Law enforcement, regulators, and authorities: where we are required by law, or where disclosure is necessary to investigate fraud, stolen vehicles, or other serious wrongdoing.
• Professional advisors: our lawyers, accountants, and insurers, where reasonably necessary.
• A successor in business: if we sell or restructure Second Gears, your information may be transferred to the acquiring business. We will tell you if this happens.

6.4 We never sell your personal information

We do not sell your personal information to data brokers, list builders, or marketers.

7. International transfers

Some of our service providers are based outside the UK, primarily in the United States (Stripe, Google, Meta, Mailchimp, Cloudflare) and other jurisdictions (TikTok). This means your personal information may be transferred outside the UK.

Where we transfer personal information outside the UK, we rely on one or more of the following safeguards, as required by UK GDPR:

• a UK Government "adequacy decision" recognising the destination country
• the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses with the UK Addendum
• other lawful transfer mechanisms permitted by UK GDPR

You can ask us for a copy of the safeguards in place for any specific transfer by emailing [email protected].

8. How we keep your information safe

We take the security of your information seriously. We use:

• encryption in transit (HTTPS) across the Platform
• Stripe for payment processing, so we never see or store your full card details
• access controls and staff confidentiality obligations
• security protections provided by our hosting provider (Cloudflare), including DDoS mitigation and firewall rules
• ongoing monitoring for suspicious activity

No online service is completely secure. If we become aware of a personal data breach that is likely to result in a risk to your rights, we will notify the ICO within 72 hours as required by law, and we will tell you without undue delay if the risk to you is high.

9. Cookies and similar technologies

Cookies are small files stored on your device that help websites work and collect information about usage.

Strictly necessary cookies are used to make the Platform work (for example, keeping you logged in and processing payments). These are always on and cannot be turned off.

Analytics and advertising cookies are used with your consent to help us understand how the Platform is used and to measure and target our advertising. These include cookies and pixels set by Google Analytics 4, Google Ads, Meta Pixel, and TikTok Pixel.

You control these through our cookie banner when you first visit the site, and you can change your choices at any time from the cookie preferences link in the site footer. Our separate Cookie Policy gives full detail.

10. How long we keep your information

We keep personal information only for as long as we reasonably need it. The table below sets out our standard retention periods. Where different periods apply by law, we follow the law.

When we no longer need your information, we either delete it or anonymise it so it can no longer be linked to you.

11. Your rights

Under UK GDPR, you have the following rights:

• Access: ask for a copy of the personal information we hold about you.
• Correction: ask us to correct inaccurate or incomplete information.
• Deletion: ask us to delete your personal information ("the right to be forgotten"). This right is not absolute — we may need to keep certain information, for example for tax or fraud-prevention reasons.
• Restriction: ask us to stop using your information in certain ways while we look into a concern.
• Objection: object to our processing where we rely on legitimate interests, and at any time to our sending you marketing messages — you can always opt out by clicking "unsubscribe" in any email or by emailing us.
• Portability: ask for a copy of information you gave us in a machine-readable format, so you can move it to another service.
• Withdrawal of consent: where we rely on your consent (for example for advertising cookies), you can withdraw it at any time.
• Automated decisions: we do not make decisions about you that have legal or similarly significant effects based solely on automated processing.

To exercise any of these rights, email [email protected]. We will respond within one month. We may need to verify your identity before we can act on a request.

If you are not happy with how we have handled your information, you can complain to the ICO:

We would prefer to resolve any concern directly — please contact us first.

If you are in the Republic of Ireland, you can alternatively contact the Irish Data Protection Commission (dataprotection.ie).

12. Children

The Platform is not intended for anyone under 18 and you must confirm you are 18 or over when you register (this is set out in our Terms and Conditions). We do not knowingly collect personal information from children. If we become aware that a user is under 18, we will delete their account and associated personal information.

13. Links to other websites

The Platform may contain links to other websites, and buyers and sellers may contact each other through third-party channels (such as WhatsApp, email, or phone). We are not responsible for the privacy practices of other websites or communication channels and we recommend you read their privacy policies.

14. Changes to this Policy

We may update this Policy from time to time. When we do, we will change the "Last updated" date at the top. If the changes are significant, we will let you know by email or through the Platform.

15. Contact us

If you have any questions about this Policy, or would like to exercise any of your rights: