Privacy Policy

Privacy Statement

UAB “PLC Group” respects your privacy and is committed to protecting your Personal Data, which is any information that can be used to identify or potentially identify a particular person.

The scope of this Privacy Policy relates to any Personal Data that “PLC.Auction” processes under applicable data privacy laws. This Privacy Policy applies to your use of this website and all “PLC.Auction” services, regardless of how you access or use the services, including access via mobile devices and applications. Unless otherwise specified, these rules apply to the activities of UAB “PLC Group”, related to vehicles physically located in the territory of various states, but under the jurisdiction of the law of the Republic of Lithuania of the European Union, in connection with the activities of UAB PLC Group.

This version was last updated in September 2022. We may update this notice from time to time, and if we do so, we will upload a new version to our website.

Important Information

This website is not intended for children, and we do not knowingly collect data relating to children. When you register with «PLC Auction» as a member, you acknowledge that you are of legal age to make bids on vehicles and further agree to our terms and conditions.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you. This privacy policy supplements other notices and is not intended to override them.

Data Controller

UAB “PLC Group” (Referred to as UAB “PLC Group”, “we”, “us” or “our”) is the data controller that is responsible for the personal data collected and used within the scope of this policy:

Jurisdiction	Entity	Address
Lithuania, European Union	UAB PLC Group	Giruliu g. 10-201, LT-12112 Vilnius, Lithuania

Personal Data We Collect

Depending on the context of your relationship with us, we may collect different categories of data.

We collect Personal Data for the following reasons:

To provide you with information, products, or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
As necessary or appropriate to protect the rights, property or safety of us, our members, our customers, or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

The following table describes how and why we collect data:

Data Category	Data Elements Corresponding to Data Category	How We Collect Your Personal Data:	GDPR Lawful Basis
Identity Data	Identifiers and characteristics of a protected class, including first name, last name, member number, username or similar identifier, password, title, date of birth, gender, social security number, tax ID, photo ID, driving license and passport information	Directly from an individual who corresponds with us Directly from our vendors Directly from our members Directly from an individual who sells us a vehicle Directly from an individual who pick up vehicles at one of our yards	Performance of a contract Your consent Our legitimate business interests, such as improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms Compliance with legal obligations To protect your vital interests or the vital interests of another natural person.
Contact Data	Identifiers, including your postal address, street address for vehicle pickup, email address and phone number and also your business license information.	Directly from an individual who corresponds with us Directly from our vendors Directly from our members Directly from an individual who sells us a vehicle Directly from an individual who picks up a vehicle at one of our yards	Performance of a contract. Your consent Our legitimate business interests, such as improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms Compliance with legal obligations To protect your vital interests or the vital interests of another natural person.
Financial Data	Identifiers and financial information, including credit card or debit card, mobile pay information such as PayPal and Apple Pay, and bank account/sort code details.	Directly from our members Directly from an individual who sells us a vehicle Directly from an individual who picks up a vehicle at one of our yards.	Performance of a contract Our legitimate business interests, such as improving our sites and services, and the services of our third parties who help us facilitate payments, except where such interests are overridden by your interests or fundamental rights and freedoms Compliance with legal obligations To protect your vital interests or the vital interests of another natural person.
Technical Data	Internet or other electronic network activity information, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, server logs, operating system and platform and other technology on the devices you use to access this website.	Directly and indirectly from people who visit our website (plc.auction).	Your consent. Our legitimate business interests, such as improving our sites and services and securing the safety of our website, except where such interests are overridden by your interests or fundamental rights and freedoms Compliance with legal obligations To protect your vital interests or the vital interests of another natural person.
Marketing Data	Includes your preferences in receiving marketing from us and our contracted third parties and your communication preferences. This also includes information you provide to us through one of our communication channels.	Directly from our members. Directly from an individual who corresponds with us.	Your consent. Our legitimate business interests, such as facilitating a communication channel and improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.
Vehicle Data	Includes the make, model, condition of the vehicle, and vehicle identification number (VIN), which some jurisdictions classify as Personal Data.	Directly from an individual who sells us a vehicle.	Performance of a contract. Our legitimate business interests, such as improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.
Usage Data	Internet or other electronic network activity information, including information about how you use our website, products, and services.	Indirectly from our members. Indirectly from individuals who visit our website and use our services.	Your consent. Our legitimate business interests, such as improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information such as recorded calls or CCTV recordings.	Directly from an individual who corresponds with us. Indirectly from an individual who picks up a vehicle from one of our yards.	Our legitimate business interests, such as improving our sites and services and securing our facilities, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.
Geolocation Data	Physical location or movements, such as the capture of an IP address	Directly and indirectly from individuals who visit our website (www.plc.auction).	Our legitimate business interests, such as improving our sites and services and security our website, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.
Transaction Data	Commercial information, consisting of information about your transactions with us, including information about items on which you place bids.	Indirectly from our members.	Our legitimate business interests, such as improving our sites and services, except where such interests are overridden by your interests or fundamental rights and freedoms. Compliance with legal obligations. To protect your vital interests or the vital interests of another natural person.

Special Categories

We do not collect Sensitive Data, which is information regarding criminal convictions or offenses, and we do not intentionally collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetics and biometric data. However, because some of our communication channels, such as e-mail, social media, and telephony systems allow end users to provide us with unstructured data, it is possible for «PLC Auction» to receive unsolicited Personal Data provided by the message sender. We request that you refrain from sharing Sensitive Data through any of these channels.

Sharing Personal Data

In addition to sharing your Personal Data within the PLC Group, we may disclose your Personal Data to external third parties in order to provide you with certain of the services you have requested from us. When we disclose Personal Data to an external third-party vendor for a business purpose, we enter into a contract with the vendor that describes the purpose of the processing and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. We disclose the following categories of Personal Data for business purposes to the relevant categories of third parties set out below:

Data Category	Third Party Category	Business Purpose
Identity Data	Regulatory Compliance Service Provider Vehicle Subhaulers Marketing Service Providers Data Analytics Service Providers Data Analytics Service Providers Identification Verification Service Providers Customer Relationship Management Service Providers Vendor Management Service Provider	To comply with the regulatory obligations applicable to our business operations. To perform a vehicle pickup as part of our service offering. To provide you with information regarding our products and services in which we think you may be interested. To analyze trends and performance of our website and electronic services. To ensure the appropriate individual is collecting a vehicle from us. To manage our relationship with you. To manage the vendors who help us provide our service offerings.
Professional and Employment Related Data	Regulatory Compliance Service Provider Background Verification Service Provider Benefits Administration Service	To comply with the regulatory obligations applicable to our business operations. To perform a background check that may be performed during the recruitment process. To administer benefits you sign up for.
Contact Data	Communications Service Providers Marketing Service Providers Vehicle Subhaulers Customer Relationship Management Service Providers Regulatory Compliance Service Provider Vendor Management Service Provider	To facilitate communications channels between us and you. To provide you with information regarding our products and services in which we think you may be interested. To perform a vehicle pickup as part of our service offering. To manage our relationship with you. To comply with the regulatory obligations applicable to our business operations. To manage the vendors who help us provide our service offerings.
Financial Data	Financial Service Providers	To facilitate payment for the goods or services you purchase from us or sell to us.
Technical Data	Information Technology Service Providers Data Analytics Service Providers	To effectively operate and protect our website and electronic services. To analyze trends and performance of our website and electronic services.
Marketing Data	Marketing Service Providers Social Media Websites	To provide you with information regarding our products and services in which we think you may be interested. To share content with you via our social media platforms.
Vehicle Data	Regulatory Compliance Service Provider	To comply with the regulatory obligations applicable to our business operations.
Usage Data	Data Analytics Service Provider	To analyze trends and performance of our website and services.
Sensory Data	Telephony and Communications Service Provider Video Surveillance Service Provider	To review calls with customer representatives for quality assurance. To effectively operate and protect our physical facilities.
Geolocation Data	Information Technology Service Providers	To effectively operate and protect our website and electronic services. To analyze trends and performance of our website and electronic services.
Biometric Data	Information Technology Service Providers	To secure and protect PLC Auction’s information and technology.
Transaction Data	Data Analytics Service Provider	To analyze trends and performance of our website and services.

In addition, we may also disclose your Personal Data in the following circumstances:

In connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of the business’s assets, change in corporate control, or insolvency or bankruptcy proceedings).
To enforce our terms of service or rules; to ensure the safety and security of our users and third parties; to protect our rights and property and the rights and property of our users and third parties; and to comply with legal process, including pursuant to a judicial warrant, rule, order or subpoena, or in other cases if we believe in good faith that disclosure is required by law or regulation, in each case, without obligation to contest such legal process.

Promotional Marketing

Depending on the location in which you are located and, if applicable whether you provide your affirmative consent, we may use your identity, contact, technical, usage and transaction data to form a view on what products or services we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you.

Withdrawing Consent for Promotional Marketing

Depending on the location in which you are located, we have established a preference center through which certain of our members may opt-out of direct marketing. The same category of members may also opt-out of promotional marketing by submitting your request to [email protected]. All recipients of marketing and promotional communications from us may opt-out of future marketing communications by clicking on the “remove me” link that we include at the bottom of all of our marketing communications.

International Transfers

For the purposes of the General Data Protection Regulation (GDPR), some recipients of your Personal Data are located outside of your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring Personal Data to such recipients, we provide appropriate safeguards.

The transmission of Personal Data between and among certain members of the PLC Auction, which consists of PLC Group. and its direct and indirect wholly-owned subsidiaries, is based on our worldwide data protection principles contained in our Intra-Group Processing Agreement, which incorporate both controller to controller and controller to processor model clauses prescribed by the European Union. Through our Intra-Group Processing Agreement, the PLC Group undertakes to protect your Personal Data and to comply with applicable data protection obligations.

Your Rights and Choices

Subject to possible restrictions under national law, as a data subject under the GDPR, you may have certain rights regarding the Personal Data that we collect on you.

Those rights are described in the below table:

Rights under GDPR	Description
Access / to Know	A consumer has the right to request that a business that collects personal information about the consumer disclose: (1) The categories of personal information it has collected about that consumer; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling personal information; (4) the categories of third parties with whom the business shares personal information; and (5) the specific pieces of personal information it has collected about that consumer.
Rectification	An individual may request that inaccurate personal data be corrected or rectified.
Deletion/Erasure	A consumer has the right to request that a business delete any personal information about the consumer that the business has collected from the consumer.
Restrict Processing	In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data: where you believe the personal data we hold about you is inaccurate and while we verify accuracy; where we want to erase your personal data as the processing is unlawful but you want us to continue to store it; where we no longer need your personal data for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.
Data Portability	In certain circumstances, you shall have the right to receive the personal data concerning you, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller.
Object to Processing	In certain circumstances, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
Object to Automated Decision-Making	In certain circumstances, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you. However, PLC Auction does not utilize automated decision-making in the processing of your Personal Data.
Withdraw Consent	In certain circumstances, you may withdraw your consent to the processing of personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you certain products or services.

Exercising Your Rights

You may generally exercise one or more of your rights described above free of charge. When requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge an appropriate fee in accordance with the applicable regulations or refuse to process the application.

To exercise your rights as a data subject under the GDPR, please submit a verifiable consumer request to:
[email protected].

Additionally, as a data subject under the GDPR, you have the right to lodge a complaint with your applicable supervisory authority. However, we would appreciate the chance to deal with your concern before you approach a supervisory authority so please contact us in the first instance.

Cookies and Similar Technologies

When you use our services, except as described in this Privacy Policy regarding the opt-in consent we obtain from certain of our web site visitors based on their location, we and selected third parties may use cookies and similar technologies to provide you with a better, faster, and safer user experience or to show you personalized advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you use the services.

Our cookies and similar technologies have different functions:

They may be technically necessary for the provision of our services;
They help us optimize our services technically (e.g. monitoring load times and errors);
They help us improve your user experience;
They allow us to show you more relevant advertisements.

Third-Party Cookies

The third-party advertising and marketing companies with which we partner may provide you the option to opt out of the use of information about your website visits and app usage for purposes of serving ads that are targeted to your interests. You can learn more about interest-based advertising and how to opt out of the use of your web browsing activity for interest-based advertising purposes by visiting these sites: Digital Advertising Alliance, the Network Advertising Initiative, and the Interactive Advertising Bureau (IAB) Europe.

Online Tracking

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We generally do not recognize your choice to opt out of tracking via a DNT request. However, depending on your location we may request that you expressly opt-in to cookies that are not essential to our web-site functionality, including tracking and marketing analytics cookies.

Data Security and Data Retention

We implement and maintain reasonable security measures to prevent your Personal Data from being used, accessed, altered, or disclosed in an unauthorized way. Please note that any information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware that despite our best efforts, no security measures are perfect or impenetrable.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

If You Fail to Provide Personal Data

When we need to collect Personal Data by law, or under the terms of the contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. For example, if you do not provide us with required Personal Data, we may be unable to provide you with the services you have requested. In this case, we may have to cancel a contract you have with us, but we will notify you if this is the case.

Non-Discrimination

We will not discriminate against you for exercising any of your Personal Data rights. Unless permitted under applicable law, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably conclude that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing [email protected].

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to this Privacy policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will notify you by email or through another appropriate communication method.

Contact Information

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions regarding this privacy policy, including any requests to exercise your legal rights. If you have any questions or comments about this policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under the GDPR, please do not hesitate to contact the DPO at:

PLC Group, UAB

Phone: +370(5)207-57-89

Email: [email protected]