Privacy Policy | Wiltshire | Penton Motor Group

Penton Motor Group Privacy Policy

1. About this privacy policy

1.1We appreciate your interest in our products and services, and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.

1.2This privacy policy applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations.

1.3We take the privacy of your personal information very seriously and will only use your personal information in accordance with the current data protection law in the UK and this privacy policy.

1.4This Penton Motor Group privacy policy sets out how :

  • what personal data we process about you, the reason we process that personal data, our legal basis for processing that personal data, and how long we will process it for;
  • who to contact in the event that you have any queries relating to your personal data;
  • who we may share personal data with;
  • the extent to which we transfer personal data outside the European Economic Area;
  • the extent to which we use personal data to carry out any automated decision making with a legal or similarly significant effect on you as a data subject; and
  • what rights you have in relation to your personal data, and how to exercise them.
  • for the purposes set out in the table below;
  • in reliance on the lawful basis set out in the table below; and
  • for the time set out in the table below.
  • we have compelling legitimate grounds to process that personal data which override your interests, rights and freedoms; or
  • we require to data for the establishment, exercise or defence of legal claims.
  • If we are not yet processing your personal data (i.e. because this is your first contact with us):
  • If you previously opted-in to marketing or did not opt-out at the time you gave us your details (as the case may be):

1.5This policy may change, so please check this page from time to time to ensure you're happy with the changes. We recommend you regularly check for changes and review this policy when you visit our website.

2.Who are we, and how do you contact us.

Data controller, address and registered number:

2.1 The Penton Motor Group trading name, represents :

Penton Securities Ltd, also trading as Penton Bournemouth, Penton Poole, Penton Citroen, Penton DS. Limited company registered in England under company number : 02846221

Wilson Investment Holdings Ltd, also trading as Penton Salisbury, Penton Citroen. Limited company registered in England under company number : 02264601

Penton Salisbury Ltd, also trading as Penton Salisbury, Penton Vauxhall. Limited company registered in England under company number : 3403618

Whenever you deal with one of the companies or trading names, the data controller of your information will be the Penton Motor Group.

You can contact us via telephone on 01202 431883, by email on datacontroller@pentonmotorgroup.com or by mail at the address above.

2.2 Where this policy refers to "we", "our" or "us" below, unless it mentions otherwise, it's referring to the particular company that is the controller of your personal information.

3. How and What Personal Information we Collect

3.1 We may collect and process the personal data set out in section 4. below:

Personal information you give to us: This is information about you that you give to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products.

Personal information we collect about you: We may automatically collect the following information : our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and , for security reasons, e.g. to identify attacks on our website, the Internet Protocol (IP) address assigned to you by the internet service. We collect some of this information using cookies - please see Cookies in Section 9.1 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.

Personal information we may receive from other sources: We obtain certain personal information about you from sources outside our business which may include PSA Group Companies, or other third party companies; the personal information received is as described in the two paragraphs above.

4.How we use Personal Information

Typeofpersonal data

Purpose

Lawful basis for the processing

How long we keep it

Your name, contact details, your purchase history and records of communication you have had with us.

For administrative purposes if you are a current or past customer, including to:

  • provide or managea product or service you have asked for; and

Necessity to perform our contract with you.

Failure to provide such data where we request it may mean we are unable to supply you with the requested product or service.

Seven years from the date on which we supply goods or services to you.

If you do not purchase from us, 12 months from your last interaction with us.


  • help us to identify you when you contact us.



To carry out credit checks where you are purchasing products on credit terms.

Our legitimate interest in preventing default.

Seven years from the date on which we supply goods or services to you.


Please note that this only applies to trade accounts. Consumer credit is offered by our third party credit partners.




To help us recover debts due to us from you.

Our legitimate interest of recovering money due to us.

Seven years from the date on which we supply goods or services to you.


To bring or defend legal claims.

Our legitimate interest of bringing or defendinglegal claims.

Where you purchased a product regulated by the FCA, 10 years from the date you bought that product.




Otherwise, seven years from the date you last dealt with us.


To contact you about products and services offered by us, using one or more of:

  • post;
  • phone;
  • e-mail; or
  • SMS,

Your consent.

Two years from the date on which you last gave your consent to marketing, although we may retain limited records to the extent required to maintain suppression lists.


dependent on the permissions you have given us.




Our current products and services include but are not limited to:

  • vehicle sales;

motor related products and services, including (amongst other things) vehicle Aftersales care, finance, leasing, ancillary insurances, vehicle accessories, vehicle emergency service, vehicle warranties and motor insurance; and parts

personal finance products.



Your purchase history.

History about email or website content you havepreviously engaged with.

Market research, which may include customer analysis and profiling.

To helpus improve our content, products and services, which may include profiling.

Our legitimate interest of researching what content, products and servicesis/are popular, andto help us improve our content, products and services.

We only retain market research in an anonymised form.

To identify other products or services you might be interested in for the purpose of direct marketing, which may include profiling.

Consent

Seven years from the date on which you last gave your consent to marketing, although we may retained limited records to the extent required to maintain suppression lists.

Your IP address, the web site from which you visit us, the web pages you actually visit and the date and length of your visit.

To help us secure and managethe performance of our websites.

Our legitimate interest of securing and managingthe performance of our websites.

Thisdataisonly stored anonymised.

Your name, contact details, and personal documents enabling us to prove your identity, which may include your passport, driving licence, and / or national insurance number.

To help us detect and prevent fraud.

Our legitimate interest of preventing loss.

Seven years from the date on which we supply goods or services to you.

All relevant documents demonstrating the provenance of any values of cashyou pay us in excess of £1,000.

This is likely to include your name, contact details, bank details, and key information and documents in respect of your financial status.

To help us detect and preventmoney laundering.

Necessary for us to comply with a legal obligation.

Failure to supply this information where we request it may result in us being unable to sell you the requested product or service.

Seven years from the date on which we supply goods or services to you.

Where multiple retention periods apply to one category of data, the retention period will be the longest one (although we will stop using that category of data when the retention period for that purpose expires).

With regards to the items with a grey background either: (a) you may have the right to object to processing; or (b) you have the right to withdraw your consent. For details on how to exercise either, please see the section below titled “Withdrawing your consent and/or objecting to our processing”.

4.1Withdrawing your consent and/or objecting to our processing

Where we originally relied on consent to process your personal data, you will always have the right to withdraw that consent.

Similarly, where we originally relied on our legitimate interests to process your personal data, you always have a right to object to our processing of that personal data. However, we do not have to stop processing that personal information following your objection where we are able to demonstrate either:

Your right to object to legitimate interests processing is however absolute if it relates to processing for marketing purposes.

We highlight where these rights apply in the table of data processing activities above, and in this paragraph we provide detail of how to go about withdrawing your consent or objecting to our legitimate interest processing.

4.2Withdrawing your consent to direct marketing, or objecting to our legitimate interest processing for direct marketing purposes

Below we set out the easiest way to withdraw your consent to, or opt-out from, marketing communications.

However, you can always contact us by calling us on 01202 431883, emailing us at datacontroller@pentonmotorgroup.com or writing to us at: Customer Care Dept, Penton Motor Group, 141 Somerford Road. Christchurch Dorset BH23 3PY.

You can opt out of receiving marketing communications from us by ticking the appropriate box on the form which you complete (whether on our website/ In-house Dealer Management System (Pinnacle). by text message or via a paper form), or by contacting us at any time using the details set out above.

You can withdraw your consent or opt-out by clicking the unsubscribe link which we include on all of our electronic marketing communications, or by contacting us at any time using the details set out above.

Please be aware that you may opt-out of all marketing from Penton Motor Group, or from marketing from certain brands within the Penton Motor Group. If you only opt-out of marketing from specific Penton Motor Group brands, you may continue to receive marketing from other Penton Motor Group brands that you previously opted-in to marketing from.

4.3 Objecting to non-marketing legitimate interests processing

To object to any of our non-marketing processing based upon our legitimate interests (as highlighted in the processing activities table above), please contact us using the contact details at Section 4.2.

5.Where we obtain your personal data from

We obtain personal data from the following sources:

  • you, for instance where you contact us about, or purchase, one of our products or services;
  • ourselves, for instance where we generate data about you (for instance a credit decision based on other personal data, or a data relating to the products or services we think you might be interested in);
  • from other dealers within the Penton Motor Group of companies for administrative purposes;
  • occasionally from other third parties who may lawfully pass to us information about you, but never for marketing purposes; and
  • If you apply for a position with us or another of the Penton Motor Group of companies.
    • our other trading divisions, subsidiaries or parent companies;
    • regulators and government authorities such as HMRC or the police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable;
    • fraud prevention agencies or other third parties that assist us in preventing fraud or loss;
    • our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating or defending actual or potential claims or complaints;
    • a potential purchaser of one of our businesses;
    • a third party to whom we transfer our customer agreement with you;
    • third party organisations where you have agreed that we may do so, typically for purchasing a product offered by that third party (e.g. a personal finance product);
    • organisations that process your data on our behalf which are not allowed to use your data for any other purpose ( for instance, marketing agencies or data management firms) including AA Cars, PSA Finance, Vauxhall Finance, Evolution Funding, CITNOW, Car Gurus, Autotrader, Freshdesk, Cooper Solutions, Mail Chimp, Textanywhere, Dealer Web, mycarneedsa.com, Motors, Mediahawk, TWG
    • These third party product providers may share your information with us in accordance with this policy. In some cases, they will be acting as controller of your information and therefore we advise you to read their privacy policy.
    • You have the right to obtain your personal data from us except in limited circumstances. We may provide you with a copy if this concerns other individuals, or we have a lawful reason to withhold that information. Except in rare cases, we will respond to you within 30 days after we have received this request.
    • You have the right to require us to rectify any inaccurate personal data we hold concerning you.
    • Taking into account the purposes of the processing, you may also have the right to have incomplete personal data completed, by means of providing a supplementary statement or otherwise.
    • You have the right to require us to erase your personal data on certain limited grounds (including where they are no longer necessary for the purpose for which they were collected or where you withdraw your consent and there is no other legal ground for the processing).
    • Where we process personal data either on the basis of consent or contractual necessity, you provided the personal data to us, and we process that personal data by automated means, you have the right to require us to give you your data in a commonly used electronic format.
    • You have the right to object to our processing of personal data which we process on the grounds of our legitimate interests, although we do not always have to honour your objection. For more information see the section above titled “Withdrawing your consent and/or objecting to our processing”.
    • You have the right to require us to restrict the processing of your personal data on certain grounds, including where:
      • you contest the accuracy of the personal data and want us to restrict processing of your personal data while we verify its accuracy;
      • the processing is unlawful, but you request a restriction of the processing rather than erasure;
      • we (as controller) no longer need the data for the purposes of the processing, but you have told us you require us to retain that personal data for you to establish, exercise or defend legal claims; or
      • you have objected to us processing your personal data on grounds of legitimate interests and want us to restrict processing of your personal data while we consider your objection.
  • to help us recognise you as a unique visitor (not just a number) when you return to our website and to allow us to tailor content of our site to match your preferred interests, including any ‘favourite vehicles’ or ‘vehicle comparisons’ you may save; and
  • to compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally where we use cookies in this way.
    • session cookies, which are temporary cookies that remain in the cookie file of your browser, usually until you close your browser; and
    • persistent cookies, which remain in the cookie file of your browser for longer, (how long will depend on the lifetime of the specific cookie).

5.1Persons with whom we may share you data:

In general, access to your personal data will be restricted to those who have a need to access it in order to carry out their duties (for example, our customer service teams and finance teams).

However, we will also share your personal data with the following external third parties in some circumstances:

6.Transfers outside of the European Economic Area

In certain limited circumstances, we may export personal data outside of the European Economic Area for processing, and we may use third party service providers who do the same.

We only do that if there is a good reason to do it and where adequate safeguards (such as the appropriate contractual arrangements with suppliers, or adequacy decisions, depending on the destination country) are in place.

7.Your rights (with effect from 25 May 2018)

The law gives you certain rights in respect of the personal data that we hold, which you should be aware of:

If you would like to exercise any of these rights, please contact us using the details set out at the top of this policy.

8.If we can’t remedy an issue you have

Should you have any complaints or issue with our treatment of your personal data, you may lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk).

9.Penton Motor Group Ltd internet sites:

We try to keep our websites secure. However you recognise when providing your information to us through our websites, or when you send us or ask us to send you any of your confidential information by e-mail, that the internet and e-mail communications over the internet may not be secure. We cannot be responsible for any loss or unauthorised interception of information transmitted via the internet, which is beyond our control.

Our internet sites may contain links to other websites outside of our group. Our privacy policy only applies to our websites. We are not responsible for the content, privacy or security of other websites.

When you visit our web sites, our web server automatically records your IP address, the web site from which you visit us, the web pages you actually visit and the date and length of your visit.

9.1Use of cookies on Penton Motor Group internet sites:

A ‘cookie’ is a piece of information that a website transfers to the cookie file of the browser on your computer’s hard disk, so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number.

When you visit our internet sites we may send you a cookie. We may use cookies in the following ways:

Two types of cookies may be used on our internet sites:

9.2Disabling/Enabling Cookies:

You can accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our websites if cookies are disabled.

You can find information on how to disable or enable cookies by visiting www.allaboutcookies.org.

9.3Social Plugins

We use so-called social plugins (buttons) of social networks such as Facebook, Twitter, LinkedIn and Instagram.

When you visit our websites, these buttons are deactivated by default, i.e. without your intervention they will not send any data to the respective social networks. Before you are able to use these buttons, you must activate them by clicking on them. They then remain active until you deactivate them again or delete your cookies. Please see Cookies in section 9.1 & 9.2 for further details.

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

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

If you are a member of a social network and do not wish to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.

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

10. Marketing

We may collect your preferences to send you marketing information directly from us by email/SMS (where applicable) including:

if you contact us online, email, telephone, SMS, post or by visiting one of our Dealerships

if you book a test drive or request a call back

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your consent in section 4.1 & 4.2 and Objecting 4.3 above for further details on how you can do this.

Please note that if you purchase a vehicle from a manufacturer franchised dealership that is not part of the Penton Motor Group network, or otherwise give your information to such a dealership, or to a manufacturer directly, you will have a separate relationship with that organisation in respect of the use of your data and you will need to contact the organisation concerned in relation to any request you may have in regards to that organisation’s use of your data.