1. GENERAL INTRO
We are committed to ensuring that we manage your personal data professionally and in compliance with all applicable data protection laws. Part of this commitment is to ensure that there is transparency about how we process personal data. This policy includes an explanation of:
- what data we are processing;
- why we are processing it and what we do with it;
- whether we will share it with anyone else;
- whether we will transfer it outside of the United Kingdom;
- how we keep your data safe; and
- your rights.
2. ABOUT US
- Our company name is Snows Motor Group Limited, and we are located at Snows House, Second Avenue, Millbrook, Southampton, Hampshire, SO15 0BT. In this policy we have referred to Snows Motor Group Limited as: we, us, our or Snows.
- Snows is an authorised retailer for: Abarth, Alfa Romeo, BMW, Citroen, DS, Fiat, Jeep, Kia, Lexus, Lotus, Mazda, Mercedes-Benz Vans, Mini, Peugeot, SEAT, Suzuki, Toyota, Volkswagen Commercials and Volvo. A full list of our retail locations and our trading titles is available on our website: www.snowsgroup.co.uk
- For any queries concerning your data and this policy, please contact the Group Communications & Marketing Director, at the above address or by email at firstname.lastname@example.org or by 'phone on 02380 707750.
3. YOUR PERSONAL DATA
We process your personal data if we understand that you may be interested in purchasing our products or services. In this section we provide more detailed information about how we will manage your personal data.
What data do we hold about you and how have we obtained this?
- We will obtain information about you when you enquire about our products or services. Typically, the information that we obtain will be your contact details and payment information. If you choose to buy finance or insurance products from us or from companies that partner with us, we will need more detailed information including, in some cases, identity and personal financial information.
- If you are part exchanging or selling your vehicle to us, we will check your vehicle details via third party providers. These checks include vehicle mileage, condition, outstanding finance and history.
- If you have visited our website we may automatically collect some personal information including: details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies – please see Cookies in section 5 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
- Our telephone calls are recorded for training purposes and may also be used to verify any comments that were made during any conversation.
- If you use our web chat function, we will keep a record of our communications.
- We have CCTV in operation at each of our operations for security purposes. It is therefore possible that images of you will be recorded when visiting our sites.
- Sometimes you will have sent your information directly to us, but you may have provided your information a third party who, in turn, has provided the information to us.
Your data that we process with your consent?
For new customers who have purchased goods or services from us on or since 25th May 2018 and who have consented, we:
- will provide you with marketing information beyond your initial enquiry about our products and services or the products and services of our selected partners;
- will keep you informed of events that we think will be of interest to you;
- will use photographic images or video footage of you when you collect your vehicle from us and may use this material to promote our business via social media channels or via our websites; and
- will use your interaction with our website and with our chat function to identify which products and services will be the most relevant to you and deliver targeted and relevant messages to you.
- Your data that we process to comply with our contract,
- We will process your data as required to perform our contract with you. This may include processing your order with the manufacturer of the vehicle that you have chosen and for completing warranty work or other after-sales obligations such as the provision of breakdown and recovery services.
Your data that we process in your vital interests
Where it is in your vital interests, we may use your information to organise and notify you about safety and product recall notices.
Your data that we process to comply with our legal obligations
We may process your information to comply with legal obligations including assisting HMRC, the Police, the Driver and Vehicle Licensing Agency, the Driver & Vehicle Standards Agency and the Financial Conduct Authority.
Your data that we process to pursue our legitimate interests
We may process your information to allow us to pursue our legitimate interests including for:
- analysing our performance to further improve our customer services;
- training and to administer our websites;
- the prevention of fraud or other criminal acts;
- undertaking credit checks for finance and vehicle mileage/condition checks;
- the purpose of corporate restructure or reorganisation or sale of our business or assets;
- enforcing our legal rights or to defend legal proceedings and for general administration purposes;
- contacting you about contractual changes;
- contacting you by post or phone for service, maintenance & MOT reminders or by email where you are a recent customer;
- contacting you for market research and satisfaction surveys;
- (where you purchased goods or services before 25th May 2018) providing marketing information to you about our products and services or the products and services of our selected partners and to keep you informed of events that we think will be of interest to you;
- providing you with information about the products or services that you have asked us to provide – including sending you videos of your vehicle being serviced;
- responding to your enquiry concerning any of our products and services – including sending you a video of a vehicle that you have expressed an interest.
Will we share your personal data with any third parties?
- We may share your data with the relevant manufacturer or seller of the product that you have purchased or expressed an interest in purchasing and other companies within our group.
- We may disclose your information to our third-party service providers for the purposes of providing services to us or directly to you on our behalf e.g. advertising agencies or administrative service providers. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
- If we sell all or part of our business to a third party, we may transfer your information to that party to ensure that it can continue to provide information that you have requested or for any of the other purposes that we have noted above.
- We may transfer your data to government or other official bodies for the purposes of complying with legal obligations, for enforcing our rights, or for the prevention or detection of a crime.
How long do we keep your data?
- If you have expressed an interest in buying products or services from us or from our selected partners, we will retain your contact details and related information concerning your enquiry for 12 months from the date of your enquiry unless you have consented for us to keep your information for a longer period. Where you have consented, we will retain your contact details and related information concerning your enquiry for 5 years from the date that that we last had contact with you.
- If you have purchased goods or services from us or from our selected partners, we will keep the data relating to that purchase (e.g. order forms and invoices and related correspondence) for 8 years from the date of the contract.
- Voice recordings of telephone calls and CCTV images shall be kept for up to 1 year.
- Records of any discussions through our web chat facility will be kept for 2 years.
- If you have requested that we do not send you marketing information we will always retain sufficient information to ensure that we remember to comply with your request.
- The periods stated in this section 3.9 may be extended if we are required by law to keep your data for a longer period.
4. TRANSFERRING YOUR DATA OUTSIDE OF THE UNITED KINGDOM (‘UK’)
The information that you send to us may be transferred to countries outside of the UK. By way of example, this may happen if any of our servers or those of our third-party service providers are from time to time located in a country outside of the UK. These countries may not have similar data protection laws to the UK.
If we transfer your information outside of the UK in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected. These measures include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us if you would like more information about the protections that we put in place.
If you use our services whilst you are outside the UK, your information may be transferred outside the UK to provide you with those services.
You can find out more about the Cookies we use in our Cookies Policy available on the home page of our website.
You can set your browser not to accept cookies, however some of our website features may not function as a result.
For more information about cookies generally and how to disable them you can visit: www.allaboutcookies.org.
6. DATA SECURITY
We have adopted appropriate technical and organisational measures to protect the personal data we collect and use having regard to the state of the art, the nature of the data stored and the risks to which the data is exposed to human action or the physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7. LINKS TO OTHER WEBSITES
8. YOUR RIGHTS
Your right to access data
We always aim to be as open as we can and allow people access to their personal information. Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide you with:
- a description of it;
- an explanation of why we are holding it;
- information about who it could be disclosed to; and
- a copy of the information in an intelligible form – unless an exception to the disclosure requirements is applicable.
If you would like to make a ‘subject access request’ please make it in writing by email to email@example.com or by post to our Group Communications & Marketing Director at the address shown in section 2.1 and mark it clearly as ‘Subject Access Request’.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
Unless you agree a different time, we will complete your subject access request within one month.
Right to stop marketing messages
You always have the right to stop marketing messages. We will usually include an unsubscribe button in any marketing emails. If you do wish to unsubscribe, please just click the unsubscribe button and we will promptly action that request. For text messages, please text back STOP to unsubscribe. Alternatively, you can update your marketing preferences by contacting us at any-time. Our contact details are shown in section 2.
Right to be forgotten
If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified – you have the right to request that we delete the data.
Right to restrict data
If we hold personal data about you and you believe it is inaccurate you have the right to request us to restrict the data until it is verified. You also have the right to request that the data is restricted where you have a right to it being deleted but would prefer that it is restricted.
Transferring your personal data
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under 3.3 and 3.4, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information
Right to complain
You always have the right to complain to the personal data regulator, the ICO.
9. POLICY UPDATES
This policy was last updated on 11th July 2018
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