(last updated: June 2023)
Vertu Motors Third Limited is a member of the group of companies of which Vertu Motors plc is the holding company (each company being a Vertu entity).
We are committed to protecting your privacy. We will use your personal information in accordance with the Data Protection Act 2018 and the UK GDPR (as defined in The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 both as amended from time to time (together the Data Protection Legislation) and other applicable laws and regulations that relate to data protection and privacy.
Who is responsible for your personal information?
We may share your personal information with other organisations that may receive and process your personal information as a data controller in their own right. Please see below for further information.
What information do we collect?
In particular, we may collect and process the following personal information about you:
· Information that you provide by filling in forms, including those on our Website and information provided by you in response to our or third-party surveys and as feedback.
· When you enquire about a vehicle or services we collect personal information to respond to your enquiry and to process your request.
· Information contained in and records of communications between us, including e-mails, letters and text messages. We may also record calls between us for training, monitoring and quality control purposes.
· Information concerning your marketing preferences where these rely on consent.
· Information from you to enable us to process your enquiry and enable the appropriate third parties to respond to your enquiry.
· If you follow or comment on social media posts from or shared by the Vertu Group, we may collect details that are part of your public profile on social media sites.
· Details supplied by you as part of a competition or prize draw entry.
We may also collect information about your preferences in connection with our Website and your activity on our Website, for the purposes of enhancing and personalising your experience on the Website. We may provide our partners and our advertisers with aggregate information about Website users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
How do we use your personal information?
We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:
· to respond to queries from you regarding services;
· if you have enquired about a vehicle or service, to pass to a third party to allow them to respond to your request regarding the vehicle or service and/or to provide the service you have requested;
· to manage and administer the relationships between you and us;
· to notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us;
· to obtain feedback from you regarding us;
· to provide you with information regarding other services and products that are available to you from us or third parties, including follow up calls to establish your interest in any such products;
· to provide you with important services communications, including communications in relation to any purchases you make or vehicle support services; and
· to offer assistance with your enquiry or request where you have partially, but not fully, completed your submission (i.e. you have provided your details on the Website but have not submitted).
All of the above are examples of where we believe that we have a legitimate interest in doing so.
In accordance with your preferences, we may also use your personal information to provide you with information about vehicles, services, promotions and offers that may be of interest to you.
The section below entitled "What choices do I have?" explains how you can change whether to receive this information from us that is based on consent/preferences. Please note that, even if you choose not to receive this information, we may continue to use your personal information in the ways described above and below.
Your personal information may also be used by us, our employees, contractors or agents, and disclosed to third parties, in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us (or one or more Vertu entity), to investigate or prevent suspected crime or fraud, or to protect our rights, property or safety or those of our customers, employees or other third parties.
In addition, where permitted by law, we may combine the information we hold with information about you or your interests, socio-economic and socio-demographic status, online identifiers and current contact details collected by third parties such as marketing agencies and from public sources.
How long do we keep your personal information?
We will not retain information longer than we need to. In general, if you enquire about a vehicle we will keep your information for 2 years to enable us to deal with future enquiries more effectively and to deal with any concerns regarding the enquiry process.
With whom do we share your personal information?
In connection with the above uses of your personal information, we will share your personal information with third parties as described below. We will share your personal information with other Vertu entities in the Vertu Group for the purposes set out above and below.
We may disclose your personal information to third parties in connection with our business activities, including in the following circumstances:
· We may pass your personal information to third party organisations that provide services to us such as web-hosting companies, mailing vendors, analytics providers, prospecting agencies and marketing agencies, IT and telephone service providers and any third party to whom we sub-contract work or who provide services or offers to our customers on our behalf.
· We may pass personal information to external agencies and organisations (including the police and other law enforcement agencies) for the purpose of preventing and detecting fraud (including fraudulent transactions) and criminal activity. We may also disclose personal information to the police and other law enforcement agencies in connection with the prevention and detection of crime.
· We will pass your personal information to third party providers so that they can provide the service you have requested.
· In the event that we sell or buy any business or assets we may disclose personal information held by us about our customers to the prospective seller or buyer of such business or assets. If we or substantially all of our assets are acquired by a third party (or subject to a reorganisation within our corporate group), personal information held by us about our customers will be one of the transferred assets.
· We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us or to protect our rights, property or safety or those of our customers, employees or other third parties.
We may share non-personal aggregate statistics (group) data about visitors to our Websites, sales and traffic patterns with members of the Vertu Group and other parties.
Protecting your personal information
Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you.
The transmission of information via the internet is not completely secure; this risk is not specific to our Website and is common across the internet. We cannot guarantee the security of your data (including your personal information) transmitted to our Website; any transmission is at your own risk.
What choices do I have?
If you think the personal information we hold about you is inaccurate or incorrect, you can request that we correct this information (including your marketing preferences) by writing to us using the details below.
You can choose to stop receiving marketing emails or SMS messages from us by following the unsubscribe link and instructions on the respective marketing emails or SMS messages we send you. You can also ask us to stop including you in marketing campaigns using profiling by writing to us using the details below.
You can also choose to change your marketing preferences by writing to us using the details below.
These changes will not prevent all uses of your information (where we believe we have legitimate interests to use it) but if you are concerned about this you can ask us to stop all contact with you.
Access to your personal information
The Data Protection Legislation gives you the right to access your personal information. To request access to your personal information, please contact us using the details below.
Right to be forgotten
You have the right to request that Vertu Group delete your personal data in certain circumstances if you would like more information about this please contact us using the details below. If we are unable to delete your data as we believe that we are required to retain it, we will delete as much information as we are able to and will also stop sending you any further information.
Third Party sites
We do not pass on any personal information about our visitors to any other site (unless we have obtained your consent to do so). In addition, if you linked to a Website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site and contact the owner or operator if you have any concerns or questions.
Transferring your information outside of Europe
As part of the services offered to you through the Website, the information which you provide to us may be transferred to countries outside the United Kingdom and outside the European Economic Area (EEA). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that it is to a country with data protection laws which are at least as stringent as those in England or we will put in place appropriate safeguards in accordance with our legal obligations to ensure that your personal information is adequately protected irrespective of the country to which it is transferred. These safeguards may include obtaining contractual assurances from any third party given access to your personal information that your personal information will be protected by standards which are equivalent to those that protect your personal information when it is in the EEA.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
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How to contact us
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.