Privacy Policy Comber Courtyard Apartment takes your privacy very seriously and we are committed to protecting your personal information in line with GDPR, Data Protection and Privacy Laws.  This privacy policy aims to help you understand how we collect, use and protect your personal information when using our website or other digital platforms.  We aim to be fully transparent and to give you control over how your data is used wherever possible. Please note that this policy can change from time-to-time and that the latest version will always be available on this website.  Please review regularly for any changes that may be made. Comber Courtyard Apartment is the data controller concerning any personal information specified in this privacy policy.  Our contact details are: Comber Courtyard Apartment 5B High Street Comber Northern Ireland BT23 5HJ If you have any queries about your personal data or this privacy policy please email us at info@combercourtyard.com or call us on 028 9754 2012 (Phone lines are open from 9am until 5pm, Monday to Friday). Credit Cards We do not store credit card details nor do we share these customer details with any 3rd parties outside of our payment service providers. Cookie Policy Cookies are small bits of information that are stored by your computer through the browser.  They are regularly used as a way of the browser remembering what the browser has done in the past.  This allows your browser to attempt to optimise your experience by making features quicker for the user.  We use cookies on our site to enrich your experience by tailoring it to be closer to your needs.  They also enable us to learn about all our users so that we can expand and develop our business to be more effective in the future.  This accounts for who has seen which pages, how frequently certain pages are visited, and which are the most popular areas of our website.  These may be used to us and our third parties to show the user the most relevant advertising online. There are numerous types of cookies which exist:
  • Strictly necessary cookies – These are cookies without which the site will not operate. These allow you to perform such operations as logging in.  Without it, we could not have an effective area of the site to upload cars.  It simply wouldn’t be possible.
  • Analytical and Performance Cookies – This cookie allows third parties to collect information about visitors to allow the development of statistics, such as total site visitors or total page impressions.
  • Functionality Cookies – These are cookies who aim to help the functional operations and speed of a website.  For example, they will remember that have visited the site before and wish to remain logged in.
  • Ad serving Cookies – These cookies allow target advertisements to appear on the site. This allows third parties to optimise their adverts towards your interests.
  • Targeting Cookies – These websites record the user’s visit to the website and the browsing habits which accompany this user.  They are used to enhance advertising to the user whilst also may be used to limit the number of times you see an advert.
A cookie can not grab data from your hard-drive, damage your device, run programmes on your device or release viruses.   You can change your browser to restrict cookie usage.  Some useful links on this include: If you wish to turn off Cookies on our website, please contact us at info@combercourtyard.com. For more information on third-party advertising-related cookies and how to opt-out of them, please visit on of the following third-party websites:
  • http://www.youronlinechoices.eu
  • http://www.aboutads.info/choices
  • http://www.networkadvertising.org/choices
Our site also links to other websites.  These other sites will have their own privacy policies which will govern how the use personal information.  We do not accept any responsibility or liability for the privacy practices of these third parties. What Information We Collect and How We Use It Information you provide when placing an advert on the website
  • We collect your email address, name, address and telephone number when registering for the site.  We also collect details of the vehicle(s) you wish to sell as well as payment details and IP Address.Your email address and name are used to communicate with you as to how to use your login area which is where you can place and edit your adverts.  We will also confirm your advert has been published. Your name will be shown on your advert, but you can choose to hide this at any time by amending the options in your login area.  Browsers of the site will also be able to send email enquiries to your email address through a link on the published car details page but will be unable to see your email unless you respond.  It is intended to help you answer any queries in the process of selling the car.  You can choose to turn this feature off at any time by amending the options in your login area.  Furthermore, we will contact you via email when your advert expires to give you the option of extending the advertisement.
  • Your address and postcode are used to allow potential buyers an awareness of whether you are within the available travel vicinity for them to purchase the vehicle. You can choose to hide certain details of your location at any time by amending the options in your login area.
  • Your telephone number is published to allow browsers of the site to contact you regarding the purchasing of your vehicle.
  • Vehicle Registration Numbers are used by us to generate data about your car for ease of upload.  They also used for regulatory purposes.  You can choose not to display the Registration number in your login area should you wish to do so.  Please be reminded that if you upload a photograph of the car with the Registration Number visible, this can be seen by browsers of the site.
  • Information may be used to provide analysis so that we may further develop our website to make it a better service.
  • We do not store credit card details.  Payment details are required for you to pay for your advert.  We use third parties to manage online card payment transactions. Information is collected securely on their gateways.  More information can be found here:
  1. PayPal and their privacy policy - https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
  • We use your IP Address to make sure you are a human entity as opposed to a bot or other computer-based entity, to further develop our understanding of our customers to further our service, and to help determine your location to orientate our service more specifically to your needs.  This also allows us to limit access to the site of potential fraudsters.
Information you provide when browsing the website
  • If you place an email enquiry for any item advertised on the website, we will require your first name, last name, telephone number and email address.  This information will be passed onto the seller as well as held by Comber Courtyard Apartment.  An email enquiry clearly indicates that you are giving authorisation for your details to be passed on to the other party and that they may contact you in response to your request.
  • If you use our live chat service you may end up disclosing such information as your name, email address, telephone number or anything else which you choose to type into the service.  This information will be passed onto the seller as well as held byComber Courtyard Apartment. A live chat interaction clearly indicates that you are giving authorisation for your details to be passed on to the other party and that they may contact you in response to your request.
  • We use your IP Address to make sure you are a human entity as opposed to a bot or other computer-based entity, to further develop our understanding of our customers to further our service, and to help determine your location to orientate our service more specifically to your needs.  This also allows us to limit access to the site of potential fraudsters.
  • We may also collect information on your location whilst browsing.  We use this to analyse our current audience to better develop our current product and services.
  • We may use cookies on our site to figure out how and what you browse.  This allows us to create audiences for marketing purposes. For more information, and to opt-out, see our cookies section.
How We Use the Information Collected We use the information we collect from the user as follows:
  • To publish and maintain the website, services and products we offer and to co-ordinate our online operations including analysis, testing, statistical research and to make the site a better experience for the user.
  • To understand who uses our website and what they require most.  This allows us to develop the best new services to encourage people to buy and sell vehicles through the website.
  • To provide those customers who do wish to be contacted, relevant and appropriate email updates to optimise the experience of buying or selling a vehicle.
  • To identify the location of visitors to both optimise their experience, but also to block fraudulent use of the site.
The Basis Upon Which We Process Your Data and Information We process your data on the basis specified below.  We may process this on more than one lawful ground depending on the purpose for which we are processing it:
  • Performance of a Contract – Our service requires that we connect buyers and sellers of vehicles. Whether you buy or sell a vehicle through the website, you are entering into a contract with Comber Courtyard Apartment with regards to the use of the service.  We require the personal information to fulfil this contractual obligation, to provide the service you request and to fully manage and assist you as much as possible.
  • Consent – Where we have processed your data for marketing purposes, such as sending you communications, this is based on you having opted-in and having given us consent. You can choose to remove this consent at any time by contacting us on info@combercourtyard.com.  We will cease processing data in this case, but that does not affect any processing of data we have previously undertaken before your withdrawal.  If you have contacted a dealer or third party in any way which passes on your details to the party involved, your data may be used by them to respond to your request before we can withdraw consent.  In this event you will be required to contact them to withdraw consent of them using your personal data.
  • Legal Obligation – We process your information where it is necessary for legal or statutory requirements.  This include our co-operation with the police and trading standards.
  • Legitimate Interest – We process your information to help our services, improve the website, understand how visitors use the site, undertake marketing research, to improve security on the website and generally improve anything we can for the good of our users.  It is of legitimate interest to us to monitor communications between buyers and sellers and to assist in disputes and disagreements.
Disclosure of Your Information At all times we will refrain from passing on your data to a third party except as laid out in this policy or with your consent.  To provide our services to you, we may need to appoint other organisations to carry out services on our behalf.  We may disclose your personal information for the following purposes and circumstances:
  • We will send your information to any sellers or relevant third parties to enable them to provide you the services and products that you have consented to receive. These third parties may then transfer, process or store your personal information elsewhere, whether in the European Economic Area (EEA) or outside it, for their business purposes relative to their own privacy policies.  If you require more information or have queries relating to how these companies handle your data, please contact them and read their privacy policies.
  • We may disclose your information to other service providers we use that help us run our website and operations.  Some of these may be based outside the EEA.  We also use plugins from third party companies and information about your visit may be collected by these companies.  This also applies in cases where you are still logged in to the third-party website.  If you require more information or have queries relating to how these companies handle your data, please contact them and read their privacy policies.
  • Where your personal information has been transferred out side the EEA, we will take full and proper steps to ensure that your information is protected in accordance with this privacy policy.
  • If we have a legal obligation or to enforce other agreements or our terms and conditions, we are under a duty to disclose your personal information.
  • We may disclose your data in the case of use potentially buying or selling a business asset. This includes if a third party was to acquire all or part of the Comber Courtyard Apartment.
  • Other parties including – the police, trading standards, other public and private sector agencies, government bodies and representative government bodies, legal advisors, professional advisors and any other third party to help prevent fraud and other illegal activities.
  • Our staff will have access to your personal information to ensure our service performs its intended purpose.
Your Rights Regarding Your Personal Information You have several rights regarding your personal information in Comber Courtyard Apartment. When you exercise these rights, we will provide you information as to the action taken within 30 days of receiving your request.  If no action is taken, we will provide an explanation as to why within 30 days.  If we require the deadline to be extended, you will be informed within 30 days of request.  Your rights are as follows:
  • Right of Access – You have the right to request a copy of all personal information that we hold about you.  If we refuse this request under right of access, we will provide a reason as to why.
  • Right of Rectification – if information about you is inaccurate or incomplete, you have the right to correct these inaccuracies or complete the information.
  • Right to Erasure – in certain circumstances you can have your personal information deleted. This only applies in one of the following scenarios:
  1. Where we no longer require the information for the purpose it was obtained.
  2. Where the processing requires your consent and the consent has been withdrawn.  There must be no other legal reason for us to retain it.
  3. Where you have used your right to object to the processing and there are no higher reasons for processing.
  4. Where you have objected to the use of your information specifically for marketing purposes.
  5. Where your information has been unlawfully processed.
  6. Where we are required to erase it to meet legal obligations.
  7. You may not have it deleted if it is required for compliance for a legal obligation, where the performance of processing it is in the public’s interest or to establish a defence against legal claims.
  • Right to Restriction of Processing – In certain conditions, you have the right to restrict the processing of your data
  • Right to Data Portability – in certain conditions you have the right to have your data transferred from our Website to another organisation.
  • Right to Objection of Processing – for certain types of processing you have the right to object to the processing occurring, e.g., direct marketing.
  • Right to Complain to the Information Commissioner’s Office – you may complain at any time about the processing of your data or how a complaint is being handled if you feel we have failed to comply properly.  If you have any complaints we would advise you to contact us first at info@combercourtyard.com.  You can also lodge a complaint with the Information Commissioner’s Office (ICO). You can find details on how to submit a complaint on their website www.ico.org.uk.
Where We Store Your Data Comber Courtyard Apartment will always take all reasonable methods to ensure that your data is safe and secure always and that it is treated appropriately as described in this privacy policy. Information you provide is handled in accordance with other service providers privacy policies and may be transferred, stored and processed outside of the EEA.  When data has been transferred outside the EEA we will ensure that all safeguards possible are in place to provide appropriate protection. This may include contractual agreements being included with our service providers in a manner which is recognised as suitable by the EU. Where a third party we work with transfers your data outside the EEA, we are not responsible for the use of the data except where they act as our processor.  If you have questions regarding these third parties, please contact them and read their privacy policies. Retention Policy We will process personal data for as long as is necessary to fulfil the purpose for which it was collected for.  This includes legal, accounting, reporting and crime prevention requirements.  The time period depends on the use of the information and the services we offer.  For all personal data where you can be identified we will not hold anything longer than 10 years.  In some cases, we may anonymise your data so that it can be used for research and statistical analysis.  In these cases, you will no longer be identifiable from the data.  This data may be used indefinitely without notice to you.


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