Under UK data protection laws, personal information may only be used where one of the following applies:
You have consented to the use
We use it to achieve a legitimate interest, and our reasons for using it outweigh any prejudice to your data protection rights
It is necessary to enter into or perform a contract with you
We need to use it to comply with our legal obligations
The use is necessary for us to protect your vital interests (or another person’s)
We need to use it to perform a task in the public interest
Generally, we will process data on one of the first two grounds listed above. If we are processing on the basis of consent, you will be presented with an opportunity to consent at the point where we collect your data. You may withdraw your consent at any time through the data preference centre (see further details below). If we are processing on the basis of our need to achieve a legitimate interest, the nature of that interest is set out below.
What information do we collect?
If you visit our website
When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). We do this for the legitimate business purpose of monitoring the number of visitors to the various parts of the site and engagement levels, which in turn enables us to make improvements. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
If you email us
Any email sent to us, including any attachments, may be monitored by us for cybersecurity reasons. Email blocking software may also be used. CW Direct Car Sales] has a legitimate business interest in using your email address, and any personal data included in your message, to resolve and respond to any issues raised. Your email will be handled in line with our policies, depending on the nature of your enquiry.
Emails sent to named individuals within CW Direct Car Sales] (e.g. email@example.com) will be stored on our systems indefinitely for the legitimate business purpose of resolving your enquiry and then checking how enquiries have been dealt with, but will not be processed for any other purposes. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If you use our enquiry form
When you submit information using an online form, CW Direct Car Sales processes the data collected and stores it for 31 days for the legitimate business purpose of enabling us to access the information and deal with your request (it is then kept for a further 14 days in CW Direct Car Sales’ routine back-ups for business continuity purposes). We collect the following information:
Note to customer: insert all the personal data that you collect across your formsets, e.g., name, email address and telephone number for enquiry forms, and explain why you collect it and how long you store it in your own systems.
If you enter your postcode, CW Direct Car Sales stores the first part of it (e.g. ‘ME14’ or ‘SW1’) and links it to standard internet log information already collected (it is used for the same purposes as that information, as outlined above).
If you use our Live Chat service
We use a third party provider, Ascend to supply and support our LiveChat service. If you use the LiveChat service we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of handling customer enquiries in real time and then following up. This data is stored by Ascend for 2 years to enable us to access the information and deal with your enquiry. Ascend stores the information in the US under the EU-US privacy shield framework.
If you make a complaint to us
When we receive a complaint from a person we make up a digital file containing the details of the complaint and store it on our system. The file normally contains the identity of the complainant (together with any contact details provided) and any other individuals involved in the complaint.
We will only use the personal information we collect for legitimate business purposes, i.e. processing the complaint and checking on the level of service we provide.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for three years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Under data privacy laws, you have the rights to:
- request access to your personal data;
- request deletion or correction of your personal data; and
- request that your personal data be transferred to another person.
Our online data preference centre helps you to exercise the rights that data privacy laws give you and control your personal information. It contains five separate forms, as set out below.
• See your data
You can ask to see any personal information that we hold (known as a “subject access request”) by submitting the form on the “See your data” tab.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
• Transfer your data
By completing the form on the “transfer your data” tab, you can ask us to provide your data to a third party.
• Delete your data
You can ask us to delete the information we hold about you by completing the form on the “delete your data” tab.
• Change your data
If we do hold information about you, you can also ask us to correct any mistakes by completing the form on the “Change your data” tab.
• Marketing Preferences
On the Contact form, you can tell us how you would like us to send you marketing information, or ask us to stop marketing to you entirely.
Any data collected through the data preference centre is stored
Do we share your personal information?
Other than as outlined above (for example where we use third party service providers), we will not usually disclose personal data. However we may disclose your information to third parties in the following circumstances:
If we are under a legal or regulatory obligation to do so
If we believe you are or may be a threat to safety, security, property, our rights or the rights of others
In a merger, acquisition, change of control, joint venture or other business combination involving [CW Direct Car Sales].
How can you make a complaint about our use of data?
CW Direct Car Sales tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
Any complaints should be addressed to the Data Protection Officer using the contact details below. If we fail to resolve your complaint to your satisfaction, you have the right to contact the UK Information Commissioner. For further information on how to do that, please go to the following webpage: https://ico.org.uk/concerns.
How can you contact us?
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of [CW Direct Car Sales] collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
12 Sandilands, Chipstead, Sevenoaks, Kent, TN13 2SP
FAO Data Protection Officer