THAMES MOTOR GROUP PRIVACY POLICY

Thank you for showing your interest in our products and services. The protection and maintenance of your privacy is our priority. This policy outlines how we collect, use and protect your personal information when you visit the Thames Motor Group (Tunbridge Wells) Ltd and Thames Motor Group (Slough) Ltd companies as outlined in section 13.

Please be aware that our policy may be subject to changes. If there is a change in policy, the latest version will be updated on our site immediately for you to view.

1. About This Policy

1.1. This policy outlines how Thames Motor Group handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.

1.2. If you have any questions regarding our policy; including how to update and/or access your personal information and make a complaint, please find our contact details below.

1.3. This policy was last updated on 05 June 2018.

2. Who We Are

2.1. Thames Motor Group (‘Thames’ or ‘we’ or ‘us’) is the data controller of your personal information to which this privacy policy applies. See section 13 for the full list of Thames Motor Group companies.

3. How and What Personal Information We Collect

3.1. Personal information you give to us: Personal information you provide to us includes your full name, contact details (such as phone number, email address and home address), enquiry details and your opinion of our products. Please be aware that any personal information you provide via our websites or our social media pages or by corresponding with us by phone, email or otherwise is provided entirely voluntarily.

3.2. Personal information we collect about you: Our website is powered by G-Forces Web Management Limited (‘GForces’), our third-party web services provider. GForces is committed to ensuring that data is processed in accordance with applicable data privacy laws and is kept secure. GForces is certified to the standard of ISO27001 (an international standard for information security). GForces uses Amazon Web Services, Inc. as its cloud platform provider. All data processed by GForces is stored on Amazon’s web servers in the EEA.

When someone visits our website; GForces collects standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). These are stored against unique ids (which are strings of numbers). GForces collects this information for the legitimate business purpose of monitoring the number of visitors to the various parts of the site, the general geographic location of visitors and engagement levels, which in turn enables it to make improvements to its websites and services and provide business intelligence. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

To update your communication preferences for our products and services offerings, as Data Controllers we rely on your consent as the legal basis for processing your preferences. You must provide consent via an affirmative act (e.g. ticking an opt-in box), and for each communication method separately. GForces will assist us by ensuring that consent can be given freely and independently for communication via post, SMS, phone and email on all standard forms across its technology.

3.3. Personal information we may receive from other sources: We may receive information about you when you use any of the other websites we operate or the other services we provide. We are also working closely with other third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

GForces also uses Google Analytics to collect standard internet log information and details of visitor behaviour patterns, which are stored against unique ids (i.e. strings of numbers). We collect this information for the legitimate business purpose of monitoring website traffic and engagement levels, which in turn enables us to make improvements to our website and the way we sell our cars and services. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

For details of the purposes for which we use the personal information we receive from these sources and the legal basis on which we rely to process that information, please see the ‘How we use your personal information’ section 4.

3.4 If you use our enquiry forms

When you submit information using an online form, GForces processes the data collected and stores it for 31 days for the legitimate business purpose of enabling us to access the information and deal with your request (it is then kept for a further 14 days in GForces’ routine back-ups for business continuity purposes). We collect the following information:

Note: insert all the personal data that you collect across your formsets, e.g., name, email address and telephone number for enquiry forms, and explain why you collect it and how long you store it for in your own systems (separate from GForces).

If you enter your post code, GForces stores the first part of it (e.g. ‘ME14’ or ‘SW1’) and links it to standard internet log information already collected (it is used for the same purposes as that information, as outlined above).

4. How we Use Your Personal Information

We may use the data you provide to answer an enquiry or to administer an ongoing commercial relationship.

We may also use your personal information to tell you about changes to the site, new information, or products and services offered by Thames Motor Group that we think will be relevant to you.

4.1. Where you have provided Consent

We may use and process your personal information where you have consented for us to do so for the following purposes:

to arrange test drives or where you have requested a call back; to supply brochures and other material you have specifically requested; to contact you about vehicle parts and accessories from our parts department; to email, text message, contact you via post or telephone with marketing information about vehicles and other services and products; to share your personal information with our third-party partners for them to contact you with marketing information about their products and services 4.2. You may withdraw your consent for us to use your information for any of the marketing purposes highlighted in this section at any time. Please write or email us using the contact details given at the bottom of this privacy policy.

4.3. Where required to perform a Contract with you

Where necessary, we may use and process your personal information for the performance of a contract with you, or, in order to take the next steps at your request before entering into a contract with you including for the following purposes:

To process orders;

to exchange information for warranty/aftersales; to exchange information for rental/courtesy car usage; to allow for the provision of third party breakdown services by our recommended breakdown provider.

4.4. Where it is in your Vital Interest

If there are any urgent safety or product recall notices, we may use your personal information to communicate with you. We may also contact you where we otherwise reasonably believe this may prevent or reduce any potential harm to you as a customer.

It is in your own vital interests for us to use your personal information for these purposes. Whilst this may be subjection we will make best endeavours towards communications being in our opinion vital.

4.5. Where required to comply with our Legal Obligations

In order for us to comply with our legal obligations we will use your personal information under the following circumstances: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.

4.6. Where there is Legitimate Interest

Your personal information may be used or processed where it is necessary for us to pursue our legitimate interests as an organisation for the following purposes:

for improvement of our marketing strategy, through analysis and profiling in order to enhance and personalise your customer experience; for market research in order to continually improve the products and services that we supply to you; other than where we rely on your consent, for marketing purposes (e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms; for fraud prevention and other criminal activities; to contact you via email, text message, post or telephone for our aftersales services (including MOT and service reminders); to carry out credit checks for finance; to correspond and communicate with you; for network and information security for us to take steps to protect your information against loss or damage, theft or unauthorised access; to comply with your request in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes) for the purposes of corporate restructure or reorganisation or sale of our business or assets; for improvements on efficiency and accuracy of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you; to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and for general administration including managing your queries, complaints, or claims, and to send service messages to you.

5. Others who may receive or have access to your personal information

5.1. Group companies

We may share your information with our other companies within the Thames Group. They may use your personal information in the ways set out in ‘How we use your personal information’ in Section 4, in connection with products and services that complement our own range of products and services, for example finance or insurance products.

Please visit the ‘About us’ in Section 13 for the details of our group companies with whom we may share your personal information.

5.2. Our suppliers and service providers

We are required to pass on your personal information to our third-party service providers, agents, subcontractors and other organisations on either occasion; when a specified third party provides a service to Thames or directly to you on Thames behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.

When liaising with our third-party service providers, to provide you with all necessary services for the optimal customer experience, we have a contract in place with such third-parties, to keep your personal information safe and strictly use your details in accordance with our specified instructions.

5.3. Third parties who provide products and services

We work closely with several third parties to offer you a range of products and/or services which are complimentary to ours, to enhance your customer or visitor experience.

In the course of business, we may pass your details on to third parties such as finance providers, insurance providers, body shops, or manufacturers.

When you enquire about or purchase any of these products or services through us (e.g. via our websites), the relevant third party may use your details to provide you with relevant information concerning your enquiry or purchase and carry out their obligations arising from any contracts you have entered into with them.

These third-party product providers may share your information with us which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

5.4. Other ways we may share your personal information

We may transfer your personal information to a third party if the following circumstances arise:

the sale of some or all business and assets of Thames; business restructuring; business reorganisation; under obligation to transfer your personal information for legal purposes to the DVLA to detect or report a crime, to enforce or apply the term of our contracts. Lastly, we may have to transfer your information to protect the rights, property and/or safety of our visitors and customers.

During the duration of the process of any of the above circumstances, we will continue to take steps to ensure your privacy rights remain protected.

6. Where we store your personal information outside the EEA

6.1. In certain circumstances where our servers or third-party service providers are relocated outside the European Economic Area (EEA), we may have to proceed in the transfer of your personal information to such companies. Servers and third-party service providers outside the EEA may not have similar data protection laws to the UK.

6.2. If we transfer your information outside of the EEA in this way, we will ensure that appropriate security measures are taken so you are still entitled to your privacy rights as outlined in this policy. These steps 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. For further details concerning the actions we take to protect your privacy outside the EEA, please contact us using the details provided at the end of this policy.

6.3. If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with such services.

7. Retention Periods

7.1. If your personal information is collected, then the length of time we retain your details for is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

7.2. Personal information is not retained in an identifiable format for longer than is necessary. It may be deleted soon after collection and those records destroyed.

7.3. We will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in ‘How we use your personal information’ in Section 4.

7.4. The only exceptions to this are where:

the law requires us to hold your personal information for a longer period or delete it sooner; you action your right for your personal information to be erased (where applicable) and where Thames Motor Group is not required to retain your personal information, should any of the circumstances arise or be connected to any of the reasons described in this section 7. Please see further information on ‘Erasing your personal information or restricting its processing’ in Section 8.6.

in limited instances, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

7.5 Telephone recordings and CCTV footage will be kept for a period of 6 months.

8. Your Rights

8.1. Your ‘data subject’ rights:

Under GDPR in relation to all countries that adhere to EU law, you are entitled to a number of rights concerning the use and transfer of personal information. However, in relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Once we have received your personal information or received your request for the personal information that we have of you, we guarantee a response within 30 days.

8.2. Accessing your personal information:

By emailing or writing to us at the address at the end of this policy, you can request a copy of your personal information that we hold about you. 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 your information.

8.3. Correcting and updating your personal information:

The accuracy of your information is vital to us and we are continually working on ways to make it easier for you to review and correct the personal information that we hold about you.

If at any point you change your name, address, email address, or learn that any of the information we are holding is inaccurate or out of date, please inform us by contacting us via the contact details at the end of this policy.

8.4. Withdrawing your consent:

Where we rely on your consent as the legal basis for processing your personal information, as set out under ‘How we use your personal information’, section 4, you may withdraw your consent at any time by contacting us using the details at the end of this policy.

You can easily withdraw your consent to receive any direct marketing by simply using our unsubscribe tool found in the privacy policy section of any campaigns we send to you via email. If you withdraw your consent, our use of your personal information before you withdraw it is still lawful.

8.5. Objecting to our use of your personal information and automated decisions made about you:

As laid out under ‘How we use your personal information’ in section 4, we will only process your personal information if it is based on our legitimate interests and it is for this purpose only that we shall use it as a legal basis. If you object or wish for your personal information to be withdrawn for these purposes, you can write or email us at the address given at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your request of withdrawal or objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under GDPR, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

However, you can easily opt out of receiving direct marketing from us by using our unsubscribe tool, found in the T&Cs of all our campaigns and we will automatically comply with your request without any justifications.

You may also contest a decision made about you based on automated processing by contacting the data protection department.

8.6. Erasing your personal information or restricting its processing

In certain instances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law permits us to use your personal information for a longer duration, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information in the following situations:

Where you believe it is unlawful for us to do so, you have objected to the use of your personal information and our investigation is pending or you require us to keep it in connection with legal proceedings.

In these circumstances, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in association with legal proceedings.

8.7. Transferring your personal information in a structured data file

If we process your personal information as a legal basis based on your consent or in connection with your contract as highlighted in ‘How we use your personal information’ in Section 4, you have the right to ask us for a copy of your personal information that we hold. We will send such data to you electronically, structured and commonly used CPU readable form (such as a CSV file).

If you request us to send your personal information directly to another service provider, we will do so if this is technically possible. If this concerns other individuals, or we have another lawful reason to without your personal information, we may not provide you with a copy.

8.8. Complaining to the UK data protection regulator

If you are concerned about the way we have processed your personal information, you have the right to complain to the Information Commissioners Office (ICO) by visiting the ICO website.

9. Security, Cookies, Links, Social Plugins

9.1. Security measures we put in place to protect your personal information

Technical and organisational security measures are used to protect the personal information supplied by you and managed by us against manipulations, loss, destruction, and access by third parties. We are continually improving our security measures in line with technological developments.

Please be aware that transmission of information via the internet is not completely secure. We will do our utmost to ensure your privacy remains protected however, we cannot guarantee the full protection of your personal information whilst in transit to our website. Be aware that any transmission is at your own risk.

9.2 Use of ‘Cookies’

Cookies are small files that are placed on your computer’s hard disk for record keeping purposes. When you visit one of our websites we may send you a cookie. For more detailed information regarding the cookies we use, please see our cookie policy.

9.3. Links to other websites

Our website may contain other links to third party websites run by other independent organisations. Hence, this policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access those using links that we provide). We provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use. Please be aware that we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

Additionally, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third party website.

9.4. Social Plugins

Social Plugins, or buttons, of social networks such as Facebook, Google+, Instagram, Pinterest, YouTube and Twitter are in use across our websites.

These buttons are deactivated by default, i.e. without your intervention they will not send any of your personal information to the respective social networks. If you wish to use the social plugins, (which are visually available on our website) you must activate them by clicking on them. You can decide to manually deactivate them or simply deactivate your cookies. Please see the ‘Cookies’ section 9.2 for further details regarding our use of cookies.

After activating these social plugins, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.

After this activation, the social network can retrieve data, independently of whether you interact with the button or not. A social network cannot assign a visit to websites operated by our other group companies unless and until you activate the respective button there as well.

If you have an account with any of the above mentioned social networks and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.

We have no influence on the data that is collected by the social networks through their buttons. Please review the policies of the social networks which provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.

10. Marketing

10.1 We may collect your preferences to send you marketing information directly from us by email, text message or letter (where applicable) including:

If you make an enquiry online;

If you book a test drive or request a call back, book a service or MOT online or via the phone We shall only do so if you have consented to receiving direct marketing information from us.

10.2. By using your personal information, we may use targeted marketing online, using different social media platforms (operated by third party companies) so we can improve the relevance of our offers to you. If you object to the use of your personal information for targeted marketing, email or write to us at the address given at the end of this Policy.

10.3. We will only share your personal information with recommended third parties for them to contact you with marketing information about their products and services where you have indicated your consent to do so. Once shared, the relevant third party’s privacy policy will apply to their processing of your personal information and we will no longer hold responsibility of how your personal information is processed. If you wish to opt-out of receiving marketing from a third party after providing your consent, you can do so at any time by contacting the relevant third party directly.

10.4. You will receive marketing from our recommended third parties only if you have chosen to opt-in.

10.5. We may periodically ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

10.6. You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see the “Withdrawing your Consent” section 8.4. Please refer to Section 8.5 above for further information on how to object to the use of your personal information for marketing purposes and any other automated decisions.

11. Changes to this policy

We may review this policy periodically and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Changes will take effect 7 days after the date of our notification/date of modified terms on our website, whichever is earlier. Please ensure you check regularly for changes and review this policy each time you visit our website. You must promptly notify us if you do not agree to any aspect of the updated policy.

12. Contact Us

If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing preferences, please use:

Data Protection Enquiries

Thames Motor Group

North Farm Industrial Estate
Longfield Road
Tunbridge Wells
Kent
TN2 3EY

Email: data@thamesmotorgroup.co.uk

Telephone: 01892 549 766

13. Thames Motor Group Companies

Thames Motor Group (Tunbridge Wells) Ltd

Registered Address: North Farm Industrial Estate, Longfield Road, Tunbridge Wells, Kent, TN2 3EY

Registration Number: 03580726

Thames Motor Group (Slough) Ltd

Registered Address: North Farm Industrial Estate, Longfield Road, Tunbridge Wells, Kent, TN2 3EY

Registration Number: 03767502

Website: www.thamesmotorgroup.co.uk

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