Who we are:
group of companies, including the following associated companies registered in England and Wales:
Halliwell Jones Limited (including its trading division Company number: 02043705
Premium Trade Cars)
59/61 Southport Road
Halliwell Jones (Chester) Limited Company number: 02665815
Halliwell Jones (Warrington) Limited Company number: 03323081
Halliwell Jones (North Wales) Limited Company number: 01266292
Tremarl Industrial Estate
Halliwell Jones (Wilmslow) Limited Company number: 00398803
130 Manchester Road
Halliwell Jones (Wilmslow) Bodyshop Limited Company number: 02575743
130 Manchester Road
and any holding company or subsidiary of such companies. Any reference to the “Company”, “we” or “us” refers to this group of companies – or where intended to identify the data controller of any personal information, will refer to the group company to whom you provided your information, which will be made clear on any sales paperwork, website sign-up form or other documentation.
The Company and personal information: we are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website) sets out the basis on which we will process any personal information about you or individuals generally - whether it’s information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.
Registration: While the Data Protection Act 1998 requires us to be registered with the Information Commissioner’s Office, we will remain registered. We will also comply with any successor notification requirements.
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
DATA PROTECTION PRINCIPLES
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:
processed fairly, lawfully and in a transparent manner;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- adequate, relevant and limited to what is necessary;
- accurate and, where necessary, kept up to date;
- not kept for longer than necessary; and
- processed securely, maintaining integrity and confidentiality.
SOME BASIC DEFINITIONS WE USE IN THIS POLICY
Personal information: In this policy, when we use the term “personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning a someone’s sex life or sexual orientation.
THE KIND OF PERSONAL INFORMATION WE HOLD ABOUT YOU
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Job title and place of work
- Demographic information such as your postcode
- Information relevant to customer surveys and/or offers and services
- Date of birth
- Marital status and dependants
- Bank account and debit/credit card details
- Information about your use of our information and communications systems
- Details of transactions you carry out through our website or by other means, the fulfilment of your instructions and any subsequent communications with you about any of these.
- Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own administrative purposes or otherwise and the resources that you access.
- We may record telephone conversations for training and security purposes. You will be notified if recording is taking place at the commencement of any call.
- Closed circuit television recordings within our premises for safety and security purposes.
We may also collect, store and use the following sensitive personal information:
- Information about any medical condition that is reportable to the DVLA and is therefore required to be declared prior to any test drive and receipt of loan vehicles
- Information about health, including any medical condition, where we enter into discussions about sales of specially-enabled vehicles for disabled customers
HOW IS YOUR
PERSONAL INFORMATION COLLECTED?
In the course of
our business, we may collect personal information directly from an
when you provide information in relation to the purchase of goods, or in relation to services we might provide to you;
when you submit an enquiry about our goods or services;
when you sign up to our mailing list; and
when you provide personal information directly to members of our team.
We may also collect personal information about individuals from other sources such as:
information provided to us by marketing agencies; and
information provided to us by referrers.
We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it - and we will keep it only as long as is necessary.
HOW WE WILL
USE PERSONAL INFORMATION
We will only use personal information
when the law allows us to do so and relying on a relevant basis for
lawful processing in each instance. We will use your personal
information in the following circumstances, relying on the basis of
Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.
To provide you with information, products or services that you request from us (contact details).
To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to personalisation or relationship status).
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party, such as any finance house or manufacturer on whose behalf we are processing data) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
To ensure that content from our website is presented in the most effective manner for you and for your computer (online identifiers, location data and other technical information).
To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences or relationship status).
To allow you to participate in interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
To notify you about changes to our service (contact details).
To maintain a basic amount of information about you and your transaction history, in order to provide you with a service tailored to your preferences (contact details, payment history and any information relating to personalisation or relationship status).
Basis of processing: Where we need to comply with a legal or regulatory obligation.
To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
Basis of processing: Where you have consented to the processing.
To send you direct marketing communications via email, text message, fax or automated call (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
Other issues about how we use personal information:
Please note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact our ICO (as defined below) if you need details about the specific legal basis we are relying on to process your personal information – contact details are below.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact us if you would like further details of any additional purposes of processing. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Where we need to collect personal information by law, or under the terms of a 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, to provide you with goods or services). If this happens, we may have to cancel, or be unable to provide, any goods or services you have requested.
Please note that we may process your personal information without your knowledge or consent where required or permitted by law.
If you provide us with any personal information relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal information may be shared with us and to provide them with appropriate information about how their personal information may be processed by us.
As indicated above, we may use your personal information to provide you with information about goods and services which may be of interest to you and we may contact you about these by post, email, text or telephone. This is known as direct marketing.
Examples of direct marketing may include:
sending promotional emails about new products, special offers, customer events or other information which we think you may find useful or interesting using the email address which you have provided;
contact you for market research purposes (by email, phone, text or mail).
We will only process personal information for the above purposes with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to third parties (including associated companies, as this term is explained at the start of this policy), and any marketing agencies or goods manufacturers for the purpose of direct marketing. Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
In this Policy, where we need your consent, we will make sure that the consent:
is specific consent for one or more specified purposes; and
is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal information.
HOW WE USE SENSITIVE PERSONAL INFORMATION
Protection for sensitive personal information: Processing of sensitive personal information requires higher levels of protection. We may process sensitive personal information about an individual in the following circumstances:
Specific sensitive personal information we process and why we are allowed to do this:
individual has explicitly consented:
- We will process information about an individual’s physical health, or disability status, to provide appropriate adjustments when designing and manufacturing any customised vehicles.
- We will process information about an individual’s physical health, or disability status, in particular any conditions that may be reportable to the DVLA, in order to ensure health and safety when allowing test drives of vehicles or providing vehicles on loan.
Automated decision-making takes place when an electronic system uses personal information to make a decision relevant to you without human intervention.
We do not
envisage that we will use any automated means to make decisions about
you, however we will notify you in writing if this position changes.
Transfer of personal information outside of the EEA: We may transfer certain personal information that we hold on individuals living in the European Union to a country outside the European Economic Area ("EEA"), provided that one of the following conditions applies:
the country to which the personal information is transferred ensures an adequate level of protection for that individual’s rights and freedoms;
an individual has given their explicit and informed consent having had the risks explained to them;
the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the EEA.
Why we might share your personal information with third parties: We may share personal information we hold with any of our associated companies (which term is described at the start of this policy). We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share personal information with other of our associated companies as part of our after-sales service and repeat sales activities. When appropriate, we will anonymise personal information when used for performance reviewing and reporting activities.
We may also share personal information we hold with selected third parties for the purposes set out below.
Third party service providers who may process your personal information: When we use the term “third party”, we mean any entity who is not one of the associated Halliwell Jones companies listed at the start of this policy, including third party service providers and contractors. The following third party service providers may process personal information for the following purposes: