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1.1 Jardine Motors Group takes its obligations with regard to data protection seriously. As such, we are providing this notice (“Privacy Notice”) to you so that you are provided with information about how Jardine Motors Group collects and processes your Personal Data in accordance with the UK General Data Protection Regulation (“UK GDPR”). Please read this Privacy Notice, as it contains important information that you need to know.
1.2 We have set out our contact details at the end of this Notice which you can use if you have any queries relating to how to access your Personal Data under the GDPR.
1.3 This Notice was updated in May 2024.
2.1 Jardine Motors Group operates a number of individual companies which includes Lancaster plc and its subsidiary operating companies including Jardine Automotive Limited, Jardine Cars Limited, Stratstone Luxury Vehicles Limited, Jardine Specialist Cars Limited and Jardine Sports Cars Limited (the “Operating Companies”). Details of the Operating Companies can be found on the website www.jardinemotors.co.uk. All share a registered office at Jardine Motors Group, C/O Porsche Centre Colchester, Auto Way , Ipswich Road, Colchester, Essex, CO4 9HA, together being the Jardine Motors Group of companies (“Jardine Motors Group”).
2.2 Please note that references to “we”, “us” or “our” means the members of the Jardine Motors Group that process your personal information, being any Jardine Motors Group company or dealership that supplies details about, or provides, vehicles, accessories, parts and/or related services to you, and Lancaster plc.
2.3 In this Privacy Notice, references to “you” means the person whose personal information we collect, use and process. This includes anyone who contacts us in connection with the products and services we provide or otherwise interacts with us about them including, for example, at any of our dealerships.
2.4 Jardine Motors Group is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you.
3.1 In order for us to provide our products (including vehicles and parts) and our services to you, it is necessary for us to collect, maintain and process Personal Data about you as a prospective and/or existing customer. “Personal Data” is information that relates to you and (either on its own or in combination with other information Jardine Motors Group holds) allows Jardine Motors Group to identify you as an individual prospective, existing and/or historic customer and thus enables us to provide our products and services, or details of them, to you.
3.2 This Notice applies to Personal Data that we collect from or about you, through the methods described below from the following main sources:
3.2.1 Our websites operated by or for us, such as sites that we operate under our own domains/URLs:
3.2.2 E-mail, text and other electronic messages which are interactions with electronic communications between you and us.
3.2.3 Offline registration forms which are printed or digital registration and similar forms that we collect via, for example, postal mail, in our dealerships, contests and other promotions or events.
3.2.4 Interactions with our advertisements (e.g. if you interact with one of our advertisements on a third party website, we may receive information about that interaction).
3.2.5 In the course of our interactions with you, we may create Personal Data about you (e.g. records of your purchases of any goods and/or services from us).
3.2.6 Data from other sources which includes third party social networks (e.g. such as Facebook, Google), market research (if feedback not provided on an anonymous basis), third party data aggregators, promotional partners, public sources and data received when we acquire other companies.
3.2.7 Personal Data may be collected from monitoring devices and systems such as closed circuit television (CCTV) within our dealerships and premises. Our CCTV monitors our business premises 24 hours a day and this data is continuously recorded. Images may be monitored by authorised personnel during
working hours and can be accessed remotely at other times if required. Live feeds from CCTV cameras are monitored where this is reasonably necessary, for example to protect health and safety.
3.2.8 In the interest of ensuring the safety and security of our vehicles and passengers, we may fit dash cams to our courtesy vehicles. We believe we have a legitimate interest in doing so, as it allows us to monitor driving behavior, address insurance claims, to be used in any civil and criminal proceedings and to enhance overall vehicle security. These dashcams are installed to safeguard the interests of both the company and our customers.
4.1 The Personal Data which we process may include the following:
4.2 Personal Data will be primarily collected from you directly on a voluntary basis. However, some Personal Data may, where lawful to do so, be collected by us from third parties, public sources, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and any other third parties. We may also collect personal information about you from your use of other Jardine Motors Group websites or services. In addition, we may combine your Personal Data with other data held by third parties (such as vehicle and value data to allow us to provide vehicle valuation services). We may also buy in data for marketing purposes.
4.3 Please note that you are under no obligation to provide us with your Personal Data, but not providing such data when requested could prevent us from being able to help you, from providing information or products and/or services to you as requested and from fulfilling your order or contract with us.
4.4 We do not usually collect any Special Categories of Personal Data about you. This includes details about your race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not usually collect any information about criminal convictions and offences, with the exception of any driving or motoring offences revealed from a check of your driving licence.
4.5 For customers with a disability who are seeking to purchase a vehicle supplied by us with the benefit of zero rated VAT relief (or any other tax benefits, as amended from time to time by law), we may require proof of your eligibility (including appropriate medical information) to process the benefit(s) or otherwise to process the transaction in accordance with the scheme rules, any relevant guidance and recognised best practice.
We do not knowingly solicit or collect Personal Data from children below the age of 16. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please contact us as described below.
6.1 When you visit our websites, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the web pages you request and the date and time of those requests. This may allow us to find out which parts of the website are popular or need changing or to show you products and services of relevance to you, either on our website or through online advertising on Google, Facebook or other websites. These details are in addition to other Personal Data collected from you but, unless you register an account with us and use that on our website, your website usage details are not linked to other Personal Data we may collect about you.
6.2 Our websites use information and may also involve the use of cookies and Web beacons. Please see our Cookies Policy https://www.jardinemotors.co.uk/site/nd-cookies-policy/ for more information.
6.3 Our website allows you to interact with us in many ways, including raising customer services enquiries, emailing us if you have a question, any feedback, suggestions for us to consider as well as interacting with us through our social media accounts including Facebook, Twitter and Live Chat.
7.1 Jardine Motors Group processes Personal Data about you for a number of purposes, including:
7.2 This list is not exhaustive and may be updated from time to time.
7.3 We also may use automated decision making, where a decision is taken solely on the basis of automated processing of your Personal Data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
7.4 We use automated decision making, including profiling, in certain circumstances, such as when it is in our legitimate interests to do so, or where we have a right to do so because it is necessary for us to enter into, and perform, a contract with you. We use profiling to enable us to give you the best service across the Jardine Motors Group, including specific marketing in which we believe you will be interested. You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects for you or affects you in any other significant way. If you are seeking to exercise this right, please contact us using the details in section 16 below.
7.5 If you are a prospective customer and/or an existing customer with us, we may use automated decision making to carry out a credit check on you. In an underwriting context, profiling is routinely carried out on your personal risk information to assess your individual risk in order to make a decision about whether to provide you with the goods and/or services. We may also apply automated decision making to telematics data.
7.6 You have certain rights in respect of automated decision making, where that decision has significant effects on you, including where it produces a legal effect on you.
8.1 We will retain your Personal Data for as long as is reasonably necessary for the purposes for which it was collected. In some circumstances we may retain your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
8.2 In specific circumstances we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings with us.
8.3 We maintain a Data Retention Policy which we apply to records in our care. When your Personal Data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
9.1 The following table describes the various purposes for which we may collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that the list is not exhaustive.
WHAT WE USE YOUR PERSONAL DATA FOR | OUR REASONS | OUR LEGITIMATE INTERESTS |
Providing goods and services to our prospective andexisting customers. We may use your Personal Data:
•to manage our relationship withyou; |
| Keeping our records up to date;
|
Legal reasons. We may use your Personal Data:
•in response to legal proceedings; |
| Developing and improving how we deal with fraud, as well as undertaking our legal duties in this respect; •complying withregulations that apply to us; and •being efficient about how wefulfil our legal and contractual duties. |
Operating our business effectively. We may use your Personal Data to run our business in an efficient and proper way. This includes managing our business capability, financial position, communications, corporate governance, planning and audit. |
| Complying with regulations that apply to us;and •being efficient about how wefulfil our legal and contractual duties. |
Developing our products and services. We may use your Personal Data: •to develop and manage ourproducts and services; •to manage how we work with other companies that provideproducts and services to us andour customers; and •to find people who might benefitfrom using our products and services. |
| Developing products and services, and what we charge for them; •defining typesof customers fornew products and services; •being efficient about how wefulfil our legal andcontractual duties; and •complying withlegal regulations that apply to us. |
Competitions, marketing and other promotions. We may useyour Personal Data to provide you withinformation about goods or services (e.g. marketing communications or campaigns and/orpromotions). This can be done via means such as email, advertisements, SMS, phone calls and postal mailings to theextent permitted by applicable laws. Some of our campaigns and promotions are run on third party websites and/or social media networks. |
| Working out which of our products and services may interest you and tellingyou about them; and •defining typesof customers fornew products or services. |
10.1 We may disclose your personal information to other members of our group of companies as well as companies that are owned by our parent company and fall within the same group.
10.2 We are authorised by a number of manufacturers to market, sell and supply specific branded vehicles, accessories, parts and related services, subject to requirements imposed on us by the relevant manufacturer.
10.3 Where you have purchased goods and/or services or expressed an interest in any of the brands we represent, we may share your Personal Data with the relevant manufacturer or brand as we are an authorised retailer for these manufacturers. You can obtain a copy of the manufacturer privacy policy by contacting us as set out in section 16 below.
10.4 We may also share your Personal Data with:
10.5 If we share your information with third party partners, the third party’s privacy notice will apply to their processing of your Personal Data.
10.6 Your personal information may also be made available to third parties (within or outside Jardine Motors Group) providing relevant services under contract to us, such as marketing agencies, auditors, compliance managers, insurers, IT hosting, administration and IT maintenance providers (including those companies referred to in this Notice). These companies may use information about you to perform their functions on our behalf.
10.7 Whenever we share your Personal Data with a third party, we take steps to ensure that any third-party partners who handle your Personal Data comply with data protection legislation and protect your Personal Data just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your Personal Data or use aggregated non-specific data sets where possible.
10.8 We may perform credit and identity checks with one or more Credit Reference Agencies (CRAs).
10.9 CRA (credit reference agency) checks involve us sharing your personal information with the UK’s CRAs (Credit Reference Agencies). The CRAs will give us information about you including about your financial situation and financial history. CRAs will supply us with both public (including the electoral register) information and shared credit, financial situation and financial history information and fraud prevention information. We may use this information to assess your financial position and to verify the accuracy of the data you have provided to us. We are required to tell you that the identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail within the Credit Reference Agencies Information Document (CRAIN). The CRAIN can be found at:
Experian Limited: www.experian.co.uk/crain
Post: Experian, PO BOX 9000, Nottingham, NG80 7WF
Web Address: https://www.experian.co.uk/consumer/contact-us/index.html
Telephone: 0344 481 0800 or 0800 013 8888
You have a right to apply to the CRAs for a copy of your file. The information they hold may not be the same and there is a small fee that you may need to pay to each agency.
11.1 Your personal information may be transferred to, and stored, and otherwise processed in one or more countries outside of the European Economic Area (“EEA”). This may happen where our parent company, a manufacturer, supplier or service provider are from time to time located in a country outside of the EEA.
11.2 We are committed to ensuring that adequate safeguards are in place when transferring Personal Data outside the EEA. We will take appropriate security measures to ensure that your personal information is adequately protected in accordance with the requirements of the GDPR.
11.3 Whenever we transfer your Personal Data out of the EEA, we will ensure a similar degree of protection is afforded to it as set out in this Notice. These steps include imposing contractual obligations on the recipient of your Personal Data or ensuring that the recipient is subscribed to recognised international frameworks for the protection of your Personal Data.
11.4 Please contact us using the details at the end of this Notice for more information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
12.1 We may wish to provide you with information about new products, services, promotions and offers which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and our services.
12.2 We may collect your marketing preferences by e-mail, telephone call or message, post or text/SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
12.3 We may contact you with targeted advertising which is delivered through social media by using your personal information or use your personal information to tailor marketing which may be relevant to you, unless you object.
12.4 We may work with selected partners to display relevant online advertisements for you and our other customers on third party websites and social media platforms. To do this, we may provide our partners with an individual’s personal information in an encrypted format, which they use only to identify the appropriate audiences for our advertisements.
12.5 We have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
12.6 You do, however, have the right to opt out of receiving marketing communications at any time by:
• contacting us at CentralDataServices@jardinemotors.co.uk; or
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
12.7 We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
13.1 You have a number of rights in relation to your Personal Data.
13.2 Where our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your Personal Data for that purpose, unless there is another lawful basis we can rely on, in which case we will let you know. Your withdrawal of your consent will not impact any of our processing up to that point.
13.3 You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, exercise rights of data portability and obtain information in relation to any automated decision making and profiling or the basis for international transfers. You may also exercise a right to complain to the
Information Commissioner’s Office (“ICO”). For more information about each of these rights, please refer to the table set out below.
RIGHT | WHAT THIS MEANS |
Access | You can ask us to:
|
Rectification | You can ask us to rectify inaccurate Personal Data. We may seekto verify the accuracy of the data before rectifying it. |
Erasure | You can ask us to erase your Personal Data, but only where:
|
Restriction | You can ask us to restrict (i.e. keep but not use) your Personal Data, but only where:
|
Portability | You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you canask to haveit ‘ported’ directly to another controller, but in each caseonly where:
|
Objection | You can object to any processing of your Personal Data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate thatwe have compelling legitimate interests which override yourrights and freedoms. |
Automated decision making | You can ask not to be subject to a decision which is based solely on automated processing, but only where that decision:
However, in these situations you can stillobtain human intervention in the decision making, and we willensure measures are in placeto allow you to express your point of view, and/or contest the automated decision. |
The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consent by contacting our Customer Services team, the contact details are set out below. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
13.4 You will not have to pay a fee to access your Personal Data or to exercise any of the other rights within this section. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data or to exercise any of your other rights. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13.6 We aim to respond to any valid requests within one month unless it is particularly complex or you have made a number of requests in which case we will inform you of this and we will then aim to respond within three months of receipt of the valid original request.
14.1 We have put in place appropriate security measures to seek to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
14.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator (such as the Information Commissioner’s Office) of a breach where we are legally required to do so.
14.3 If we have provided you with a password, or if you have chosen your own password, it is your responsibility to ensure that the password is kept confidential.
15.1 We will keep this Notice under regular review. We may change this Notice from time to time by updating this Notice in order to reflect changes in the law and/or our privacy practices. The date in paragraph 1.3 at the beginning of this Notice will be updated accordingly.
15.2 We encourage you to check the date of this Notice when you visit our website for any updates or changes. We will notify you of any modified versions of this Notice that might materially affect the way we use or disclose your personal information.
Web portal: https://www.jardinemotors.co.uk/site/privacy-notice/ (Web portal to be used for Subject Access Requests only)
Email: customerservices@jardinemotors.co.uk.
Helpline: 0800 012 5050
Write to: Customer Services - Jardine Motors Group Riverview Suite
NE Business & Innovation Centre Sunderland Enterprise Park
East Sunderland Tyne & Wear SR5 2TH
If you have a complaint or concern about how we use your Personal Data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time.
Updated: May 2024