PRIVACY POLICY            LAST UPDATE May 2022

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Summary

As part of your dealings with any member of the group of companies of which Worcester Carsales Limited is the parent company (each company being a "trading entity") and to comply with our legal obligations, we will collect and otherwise process personal information about you in order to supply vehicles, goods and services to you and to administer our relationship with you. This may involve sharing your personal information with third parties. This Privacy Policy describes in detail how we will use your personal information and how you can exercise your rights with respect to your personal information.

If we decide to change this Privacy Policy, we will post the updated Privacy Policy on our websites so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it. The updated Privacy Policy will take effect as soon as it is posted on our Websites.

Introduction

In this Privacy Policy, references to we, us or our (or words of similar import) means the Worcester Carsales Ltd entity that processes your personal information (as defined below) and interacts with you (for example, the entity from whom you purchase a vehicle or other services).

The documents you receive from any trading entity will identify the business that you are dealing with and for the purposes of this Privacy Policy.

These include:

Worcester Carsales Limited T/A T Wall Garages
Worcester Carsales Limited T/A Dudley Motor Company
Worcester Carsales Limited T/A Halesowen Motor House
Worcester Carsales Limited T/A Stourbridge Motor House

Worcester Carsales Limited T/A Stourbridge Motors
Worcester Carsales Limited T/A Clarks of Kidderminster
Worcester Carsales Limited T/A Kidderminster Motor House
Worcester Carsales Limited T/A Leominster Motors
Worcester Carsales Limited T/A Ludlow Motors
Worcester Carsales Limited T/A Hyundai Birmingham West

Worcester Carsales Limited T/A Motorfair

Worcester Carsales Limited T/A Clarks of Stourbridge

In this Privacy Policy, references to you mean the person whose personal information (as defined below) we collect, use and process. This includes anyone who visits our websites, contacts us in connection with the purchase of a Vehicle and/or any goods or services we provide or otherwise interacts with us (for example, via a dealership).

In this Privacy Policy, Website refers to any website operated by or on behalf of Worcester Carsales (Holdings) Limited.

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.

We cannot be held responsible for the privacy policies and practices of other businesses even if you access those using links from our website. We recommend that you check the policy of that third party site and contact the owner or operator if you have any concerns or questions.

Who is responsible for your personal information?

For the purposes of the Data Protection Legislation, Worcester Carsales Ltd is the joint and data controller in respect of your personal information that we collect and process as further described in this Privacy Policy. All information is stored on a group database so will be shared with other organisations in the Worcester Carsales Ltd group who may act as data processors.

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?

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), vehicle details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details, payment and bill information, and bank account and credit or debit card details). We may also obtain copies of your driving licence and other identification, and your vehicle insurance details. This information is referred to in this Privacy Policy as personal information.

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 websites and those on third-party websites that contain advertisements for our vehicles, and information provided by you as part of a purchase or potential purchase on our websites, even if that purchase does not proceed.
• A copy of your driving licence when you test drive a vehicle or are provided with a courtesy car or data provided by an online checking service regarding your driving licence and any penalties.
• When you enquire about or purchase a vehicle or services, we collect personal information to respond to your enquiry and to process and complete your purchase.
• Details about the transactions you carry out with us including vehicle support services and vehicle purchases and purchases of other goods.
• CCTV footage in which you feature when you visit our premises.
• Information contained in and records of communications between us, including e-mails,     letters and text messages
• Details of your visits to our websites, including, but not limited to, traffic data, location data (including the country and telephone area code where your computer is located), IP (internet protocol) address, browser and operating system information, and the resources that you access (including the pages of our website that you view and the website from which you access our Website). For more details of how we collect data through the use of cookies, please see the separate cookies policy on our websites.  You may be able to disable the collection of some of this data through amending the web settings of your device or browser but doing so may impact the functionality of our website.
• Information concerning your marketing preferences where these rely on consent.
• Information relevant to the insurance products that we sell that are provided by third parties.
• Information from you to enable us to propose you for vehicle finance, as required by the relevant third-party finance company. This will include financial and employment information and verification documents.
• Details of diagnostic tests and work carried out on your vehicle including video footage and records of parts used.
• If you follow or comment on social media posts from or shared by the Group, we may collect details that are part of your public profile on social media sites.
• Details regarding your family members if they are provided to us as part of a vehicle purchase, or for example, if another family member is using or collecting your vehicle.
• We may be provided with personal information about you by manufacturers or finance companies if you have purchased a vehicle or enquired regarding a vehicle or work to be done.
• Information relating to any purchases you make of our goods or services, including any other transaction details made via any of our websites (including your address, telephone number and payment details)
• Information that you provide when applying for and accepting an employment position at Worcester Carsales Limited (including your name, date of birth, address, previous employment details, references, information from identity documents, bank details, background check providers and previous address details you provide);
• Records of communication between us (email, phone, SMS, letter, live chat)
• Terms and conditions of your employment including remuneration and National Insurance number
• Details of performance whilst in employment with Worcester Carsales Limited
• Information about health or medical conditions required for Us to make reasonable adjustments to accommodate this
• Details supplied by you as part of a competition or prize draw entry.

There may be circumstances when we collect special categories of personal data regarding your health, sexual orientation or criminal convictions, if you provide this information to us as part of a discussion regarding your vehicle or vehicle enquiry. In particular, if you use the Motability scheme, we may collect details about your disability and health to administer your application and verify your eligibility for the scheme.

If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.

We may collect and process information we receive about you from third parties.  This information may include your personal and financial information, your employer, companies that you are connected with (such as a Director) or other person connected with your finance application; information about the vehicle you are purchasing credit information, such as previous applications, the conduct of accounts in your  and your financial associates’ name (this is anyone linked to you for credit or finance purposes), any business accounts you have and public information such as County Court Judgements, bankruptcies and the Electoral Register.

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 the possible purchase of goods or services, including looking at your searches and history on our websites prior to an enquiry and combining the data held on our systems with your activity on our Websites and your Google ID;
• to carry out our obligations arising from any contracts entered into between you and us including purchase of vehicles and provision of services, and to respond to queries from you regarding those contracts;
• to manage and administer the relationships between you and us (or one or more of the members of the Worcester Carsales Group);
• 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; and
• to obtain feedback from you regarding us and the manufacturer of your vehicle;
  • to provide you with information regarding other services and products that are available to you from us or third parties;
• to provide you with reminders regarding your vehicle including, for example, when your   vehicle is due to have a service or MOT undertaken;
• to contact you when you may be in a position to change your vehicle, including when your finance agreement is due for renewal. In some cases, we will be asked to contact you by a vehicle manufacturer or finance company.
• management of a recruitment process
  • to check we are complying with our legal obligations

Please note that, even if you chose not to receive this information, we will use your personal information to provide you with important service communications including communications in relation to any purchases you make or vehicle support services as we have a legitimate interest and or contractual obligation to you to do this.

If you enquire about a potential vehicle purchase, lease or hire of a vehicle and/or any goods or services, we will use your information to contact you for up to 3 months about that potential purchase, lease or hire.  We may then provide your details to lenders if you wish to apply for finance for your purchase. If you go ahead and purchase, lease or hire a vehicle and/or any goods or services from us, we will use your information in various other ways, details of which are provided to you at the time of your purchase. These include:

• contacting you to obtain feedback on your purchase or other services provided;
• contacting you in the future with MOT and service reminders if you continue to use our group for servicing/MOT of your vehicle
• contacting you in the future if you may be in a position to change your vehicle.
  

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 additional 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. 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 trading entity), 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 do we make decisions using your data?

We will use your information to carry out automated decision-making and profiling in some circumstances. For example, service and MOT reminders will be automatically sent where relevant based on the vehicle and maintenance information we hold. We will also select customers for marketing campaigns and offers based on factors such as age of vehicle, type of vehicle finance held and date since last vehicle purchase as well as previous responses to marketing campaigns and Website activity.

Where you enquire about a vehicle, we will offer you vehicle finance using an average finance rate, or you can always purchase a vehicle from us using cash.

How long do we keep your personal information?

We will not retain information longer than we need to. In general, if you enquire but do not purchase a vehicle from us, 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. If you purchase a vehicle from us, or have servicing or repair work carried out, or purchase a part from us, we will keep your information for 7 years from your last transaction with us. We may keep details of a vehicle for longer than that but without it being attached to your information.

With whom do we share your personal information?

In connection with the above uses of your personal information, we may share your personal information with third parties as described below. We will share your personal information with other trading entities in the Worcester Carsales 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 are obliged to share your personal information such as your vehicle Manufacturer (*known as Independent Controller). *The Independent controller (Manufacturer) along with every Retailer / Authorised Repairer of the Brand will have access to only generic customer contact data & vehicle details to enable repairs to be completed if you are away from your local dealership.  It does not give them consent for marketing; this is purely under legitimate interest.
• 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 (such as repairs or specialist fitting) or who provide services or offers to our customers on our behalf. It will be treated in accordance with the legal provisions under English law concerning data protection and may be transferred to the USA or countries outside the EEA for the purposes of business information.
• We may share your name and contact details with Facebook and other social media sites to enable them to identify you as a customer of the Group and to assess criteria such as age and location to assist with our marketing on social media. We do not receive any details from Facebook that we do not already hold and the data would be used in a generic way only to target advertising.
• 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 may pass your personal information to third party finance companies for the purposes of them providing you with finance. Those organisations may carry credit checks and may disclose your data to credit reference agencies for that purpose.

We will pass your personal information to third-party providers of insurance products that     we offer, if you take up the option of purchasing one of those products.

•    We will provide your information to the DVSA if you buy a vehicle from us to record you as the registered keeper and to obtain road tax on the vehicle.
• If you purchase a vehicle from us, we may pass your contact and purchase information to GardX Assure Limited to enable them to offer you an asset protection policy on your vehicle.
  • If you take out an RAC Warranty or Tyre & Alloy Insurance we will pass your information to TWG Services Limited and Premia Solutions to enable them to provide the breakdown insurance included with that warranty.
• In the event that we sell or buy any business or assets (including car dealerships), 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 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 one or more members of the Worcester Carsales Group); or to protect our rights, property or safety or those of our customers, employees or other third parties;
• We may pass your personal information to the relevant franchise manufacturer partner relating to your vehicle, and in some cases whether or not you go ahead and purchase the vehicle. They may use this to register your ownership of the vehicle and to contact you directly regarding your vehicle and to obtain feedback and/or to provide offers. Most manufacturers will share your information within their group and this may include information being transferred outside of the EEA. For some manufacturers we will also ask you whether you consent to further contact from the manufacturer and pass this consent (or lack thereof) to the manufacturer. Further details about specific manufacturer use of your data is set out below.
• If you purchase a Motability vehicle, we will provide your details to Motability Operations Limited to enable them to contact you regarding your vehicle.

We may share non-personal aggregate statistics (group) data about visitors to our websites, sales and traffic patterns with members of Worcester Carsales Limited and other parties.

Protecting your personal information

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal data you provide on our secure password and firewall protected servers or in hard copy format in our secure storage areas

All details of financial transactions entered via our / third party websites will be protected by encryption technology.

We will not hold your personal information in an identifiable format for any longer than is necessary.

If you are a customer or otherwise have a relationship with us, we will hold personal information about you for a longer period than if we obtained your details in connection with a prospective relationship

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 websites 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 may instruct us to provide you with any personal information we hold about you via a written Subject Access Request.  Upon receipt of such a request we will, after confirming identity, provide all relevant data we may hold to you in the most practical format unless otherwise stipulated and reasonably possible.

We may withhold personal information that you request to the extent permitted by law.

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 Worcester Carsales Limited delete your personal data in certain circumstances, if you would like more information about this please contact us using the details below. If you have purchased goods or services from us, we will retain details of your purchase for 7 years. 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.

If you instruct us to no longer process your personal data we will do so as quickly as possible.

If you instruct us to destroy any/all of your personal data we may hold we will do so as quickly as possible.

If you instruct us to cease all processing for marketing purposes we will do so as quickly as possible.

Third Party sites

Our websites contain links to other websites. This privacy policy applies only to our websites, so visitors should always be aware when they are moving to another site and read the privacy statement of any site which collects personal information. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our websites.

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.

Cookies

Our websites use cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our website. Details of the cookies used and how we use the information we obtain are set out in our cookie policy below. You will be asked to set cookie preferences when you access one of our websites for the first time.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How to contact us

If you have any questions, comments or requests regarding this Privacy Policy, please feel free to contact us by writing to us at: Data Protection Officer, Clarks of Kidderminster, Worcester Road, Kidderminster, Worcestershire, DY10 1JR or emailing [email protected]  

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.

Manufacturer & Service Providers - specific information

We will share your information with the manufacturer of your vehicle when you purchase a new vehicle, and in certain other circumstances. We act as a separate data controller from the manufacturers and on occasion may act as a data processor for the manufacturers. If you want to update your communication preferences with the manufacturers, you will need to do this separately to any request made to us, unless you specifically ask us to communicate with the manufacturer on your behalf by email to [email protected] . Further details on how each manufacturer will use your data, and who to contact, are set out below.

Citroen: If you have enquired about or purchased a new Citroen vehicle from a Worcester Carsales Limited Citroen dealership, your information will be passed to Citroen UK Limited. They may also receive data relating to Citroen used car buyers and Citroen service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.citroen.co.uk/privacy.

Ford: If you have enquired about or purchased a new Ford vehicle from a Worcester Carsales Limited    Ford dealership, your information will be passed to Ford Motor Company Limited. They may also receive data relating to Ford used car buyers and Ford service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.ford.co.uk in the Customer Privacy Policy at the foot of each page.

Hyundai: If you have enquired about or purchased a new Hyundai vehicle from a Worcester Carsales Limited Hyundai dealership, your information will be passed to Hyundai Motor UK Limited. They may also receive data relating to Hyundai used car buyers and Hyundai service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.hyundai.co.uk/legal/privacy.

Kia: If you have enquired about or purchased a new Kia vehicle from a Worcester Carsales Limited Kia dealership, your information will be passed to Kia Motors (UK) Limited. They may also receive data relating to Kia used car buyers and Kia service or repair customers. Details of how they use information regarding customers and prospective customers can be found at https://www.kia.com/uk/Privacy/.

Mazda: If you have enquired about or purchased a new Mazda vehicle from a Worcester Carsales Limited Mazda dealership, your information will be passed to Mazda Motors UK Limited. They may also receive data relating to Mazda used car buyers and Mazda service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.mazda.co.uk/privacy-policy/.

MG: If you have enquired about or purchased a new MG vehicle from a Worcester Carsales Limited MG dealership, your information will be passed to MG Motors UK Limited. They may also receive data relating to MG used car buyers and MG service or repair customers. Details of how they use information regarding customers and prospective customers can be found at Privacy Policy | MG Motor UK

Peugeot: If you have enquired about or purchased a new Peugeot vehicle from a Worcester Carsales Limited Peugeot dealership, your information will be passed to Peugeot Motor Company plc. They may also receive data relating to Peugeot used car buyers and Peugeot service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.peugeot.co.uk/privacy-policy/.

Suzuki: If you have enquired about or purchased a new Suzuki vehicle from a Worcester Carsales Limited Suzuki dealership, your information will be passed to Suzuki GB PLC. They may also receive data relating to Suzuki used car buyers and Suzuki service or repair customers. Details of how they use information regarding customers and prospective customers can be found at https://cars.suzuki.co.uk/privacy/.

Vauxhall: If you have enquired about or purchased a new Vauxhall vehicle from a Worcester Carsales Limited Vauxhall dealership, your information will be passed to Vauxhall Motors Limited. They may also receive data relating to Vauxhall used car buyers and Vauxhall service or repair customers. Details of how they use information regarding customers and prospective customers can be found at www.vauxhall.co.uk/tools/privacy-policy.html

FREE2MOVE Rent:  If you have enquired about or purchased a new Citroen, Vauxhall or Peugeot

from a Worcester Carsales Limited dealership, your information will be passed to FREE2Move Rent. They will also receive data relating to your vehicle.  Details of how they use information regarding customers and prospective customers can be found at Privacy Policy (free2move-lease.co.uk)

eDynamix:  If you have arranged a vehicle service or repair as part of your dealings with any member of the group of companies of which Worcester Carsales Limited is the parent company, your information will be passed to eDynamix, our automotive technology partner.  They will also receive data relating to your vehicle.  Details of how they use information regarding customers and prospective customers can be found at privacy_policy.pdf (edynamix.com)

EMaC:  If you have arranged a vehicle service or repair as part of your dealings with any member of the group of companies of which Worcester Carsales Limited is the parent company, your information will be passed to EMaC, our aftersales relationship partners.  They will also receive data relating to your vehicle.  Details of how they use information regarding customers and prospective customers can be found at Privacy policy - EMaC - Service Plans and Aftersales Partners