Context and overview
What information do we collect about you?
- Your name, gender, date of birth, billing/delivery address, email address and telephone number. We may also collect information about hobbies and interests, income, and dependencies.
- Details of your interactions with us, on-site, online or through contact centres.
- Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our websites, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
- Payment card information, which are disposed immediately after payment.
- Your image may be recorded on CCTV when you visit a Retail centre.
- To deliver the best possible web experience, we might collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Where we collect your information
- When you make an enquiry with us, either in person, over the phone, by email or through our website.
- When you join a loyalty program or club (e.g. M-Performance Club or Cotswold MINI Club.)
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event.
- When you choose to complete any surveys we send you.
- When you apply for a position with us.
- When you fill in any forms. For example, if an accident happens on our premises, a team member may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you – for example BMW / MINI Group websites.
- When our Finance suppliers – e.g. BMW Financial Services – share information with us about the product you have purchased.
- When you use our Retail centres and car parks which usually have CCTV systems operated for the security of both our customers and our team. These systems may record your image during your visit.
How and why do we use your personal data?
- To process any orders that you make in our Retail centres or by using our websites. If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as warranties.
- To respond to your queries and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our customers, premises, assets and team from crime, we operate CCTV systems in our Retail centres and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This helps to protect our customers from fraud and help us recover any debts.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- We will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services. You are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any point.
- To process your booking/appointment requests e.g. for Service work or Test Drives.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our service with you. Without sharing your personal data, we’d be unable to fulfil your request.
The legal bases we rely on:
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent - In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations - In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order a part from us for home delivery, we’ll collect your address details to deliver your purchase.
Legal compliance - If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Cotswold Motor Group Ltd to law enforcement.
Legitimate interest - In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers. We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
How we protect your personal data
We know how much data security matters. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. Access to your personal data is password-protected, and sensitive data; such as payment card information is not stored or recorded during phone calls. We regularly monitor our system for possible vulnerabilities and attacks.
How long do we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will be deleted. We will continue to keep information on your vehicle, such as service history, but will delete the personal details.
Orders - When you buy from us, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations.
Inactivity - If there has been no contact with you for more than 3 years, your record will be flagged as inactive and then delete the data. Due to a change in our DMS system, all records were automatically updated to last contact being 8 Jan 2018.
Warranties - If your purchased item (Vehicle or Part/Accessory) included a warranty, the associated personal data will be kept until the end of the warranty period, or inactivity period, whichever is later.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on. We will also pass your data onto the Manfacturer (BMW or MINI) unless you ask us not to.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
To help personalise your journey through Cotswold websites we currently use the following companies who will process your personal data as part of their contracts with us:
What are your rights over your personal data?
You have the right to request:
- Access to the personal data we hold about you.
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact The Data Protection Officer, Cotswold Motor Group Ltd, Corinthinan Park, Corinthian Way, Cheltenham. GL51 6UP.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity
There are several ways you can stop communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- Write to Cotswold Motor Group, Marketing Dept, Corinthian Park, Corinthian Way, Cheltenham GL51 6UP
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us on email@example.com
- Or write to us at
Data Protection Team
Cotswold Motor Group Ltd
This policy was last updated on 14/05/18