PRIVACY AND LEGAL NOTICE
1. Important information and who we are
Purpose of this privacy notice
This privacy notice will inform you as to how we look after your personal data when you become a client and tell you about your privacy rights and how the law protects you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Hartshorne Group is the controller and responsible for your personal data (referred to as “HARTSHORNE GROUP”, "we", "us" or "our" in this privacy notice).
You 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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in May 2018
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title and your driving license details if a courtesy car is required.
- Contact Data includes address, email address and telephone numbers. In this we also class vehicle registration numbers and chassis numbers as Contact Data.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Usage Data includes information about how you use our services
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect Special Categories of Personal Data about you. We do, however, collect driving license information for insurance purposes from customers for courtesy cars. The results of these searches may highlight any criminal offenses.
If you fail to provide personal data
Where we need to collect personal data 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Enter into a contract with us;
- Enquire about our services;
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Financial and Transaction Data from Volvo Financial Services, for example for general credit checking services.
- Identity Data from submitting your driving license details to the DVLA to view your driving record.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Protection Contact.
- Where we need to comply with a legal or regulatory obligation.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Purposes for which we will use your personal data
We have set out below all of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Performance of our contract with you
- Register you as a new customer. When you ask us to perform services for you, you will provide Identity and Contact data and other information relevant to your contract.
- Liaise with Volvo Group UK and other subsidiaries of the Volvo group in order to ensure compliance with service, manufacturer recalls, warranty, or relating to vehicle safety or specification standards, for example Volvo Financial Services in order to conduct a credit check. We do not expect to process special category data.
- Manage fees, payments, fees and charges arising from your relationship with us.
· Legitimate interests
- If you have entered into a contract with us, then we may use your Identity and Contact data to tell you about similar services we offer which we think may be of interest.
- Collect and recover money owed to us.
- Maintain and secure our premises. This includes a CCTV network and reviewing footage. This is only for our security purposes.
· Legal Obligation
- We also rely on the legal or regulatory obligation ground to process your data in some circumstances. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
We strive to provide you with choices regarding personal data uses, particularly around our marketing and advertising activities.
Promotional offers from us.
We may use your Identity, Contact and Usage Data to form a view on what we think you may want or need, or what may be of interest to you if you have entered a contract with us. This is how we decide which products, services and offers may be relevant for you (we call this marketing). For example, we may wish to invite you to an event or inform you of other relevant products or services relating to your contract with us.
You will receive marketing communications from us if you have purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us at any time, details of which will be on all communications.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
Change of purpose
We will only use your personal data 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Professional advisers including lawyers, surveyors, bankers and insurers based in the UK who provide consultancy, legal and accountancy work.
- Volvo Group UK Limited including subsidiaries and dealerships associated with the group as part of a relationship where we are joint data controllers.
- Service providers based in the UK who provide IT and system administration services, who administer our IT infrastructure and ensure all systems, services, software and devices meet acceptable security standards.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances. This also applies to payment of any fines, duties, tolls, congestion charges or other sums which become payable related to your use of vehicles registered to HARTSHORNE GROUP.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Largely we do not transfer your personal data outside the European Economic Area (EEA).
However, our cloud-based service providers may have datacentres outside the EEA and the storage of your data in these databases may involve a transfer of data outside the EEA. Furthermore our third parties may process data elsewhere.
Whenever we transfer your personal data out of the EEA the data transferred is minimal, and we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data 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 certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as a data processing agreement. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use 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 data shared between the 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 data out of the EEA.
7. Data security
We have put in place appropriate security measures 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
9. Your legal rights
i. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
ii. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
iii. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
iv. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
v. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
vi. Request the transfer of your personal information to another party.
vii. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you want to exercise any of the above rights, please contact the Data Protection Contact.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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