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Inchcape Retail Privacy Policy 

1 Who we are 

We are Inchcape. Inchcape is the trading name for Inchcape Retail Limited and it subsidiary  companies including Chapelgate Motors Limited, Gerard Mann Limited and The Cooper Group  Limited. Our registered office is at First Floor, Unit 3140 Park Square, Solihull Parkway,  Birmingham Business Park, Birmingham, B37 7YN. All of the companies within the Inchcape  group are registered with the ICO as data controllers.  

We are dedicated to ensuring that all personal data that we process is done so in a fair,  lawful and transparent manner. We take the security of your data very seriously and  adhere to all relevant data protection legislation including the Data Protection Act 2018, the General Data Protection Regulation 2016/679 (‘GDPR’) and The Privacy and Electronic  Communications (EC Directive) Regulations 2003 (“PECR”). 

2 How to contact us or make a complaint 

If you have any questions relating to this notice, your rights under data protection legislation  or the processing of your personal data then you can contact us by: 

Email: data.protection@inchcape.com 

Post: FAO Data Privacy Compliance, First Floor, Unit 3140 Park Square, Solihull Parkway,  Birmingham Business Park, Birmingham, B37 7YN 

Telephone: 0333 130 0108 

You are important to us, and so is protecting your personal information. We have high standards  when it comes to collecting and using personal information. For this reason, we take any  complaints we receive from you about our use of your personal information very seriously and  request that you bring any issues to our attention.  

Where you are communicating with us for the purpose of making a complaint, we will only use  your personal information to handle, investigate and respond to the complaint and to check on  the level of service we provide. Where the complaint is about a member of our team, we may  have to disclose your identity to whoever the complaint is about. You may let us know that you  don’t want information that identifies you to be disclosed and we will try to respect your  request; however, it may not be always possible to handle a complaint on an anonymous basis. 

If you are unhappy with our use of your personal data or our response to the exercise by you of  any of your rights, then you have the right to complain the UK’s data protection authority the  Information Commissioner’s Office (ICO) (www.ico.org.uk).  

3 What is Personal Data? 

Personal data includes any information about an individual from which that individual can be  identified. Examples include your name, identification number, email or home address,  photograph and bank account details, factors specific to an individual (such as your physical, 

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physiological, mental, economic, cultural or social identity) and any data that would allow you  to be identified when combined with other data. 

It is our intention to provide you with as much information as possible about what we do with  that personal data, so that when you provide your personal data to us, you do so with an  awareness of how it will be used. 

If you provide us with personal data on behalf of someone else, for example if you provide your  spouse’s details in connection with the purchase of a vehicle, you confirm to us that you have  their permission to do so. The exercise of any further rights in connection with such personal  data will need to be done by the relevant individual.  

4 How we collect your personal information and why 

We are not interested in collecting every personal detail about you. Our main reason for  collecting your personal information is to provide and improve the service, products and  experiences that your customers expect from us. 

We will need to collect personal information about you in order for us to be able to carry out  the service you have requested or accessed. We will only collect the information that we need. 

We collect your personal information in a number of different ways which we have explained  in this section.  

Information that you share with us 

We collect personal information that you share with us when you contact or interact with us.  For example, where you provide it to us: 

by entering personal data via our website, www.inchcape.co.uk, live chat boxes or  social media platforms and testimonials and opinions you may have posted publicly 

when you contact our customer service teams and our call centre 

if you make an enquiry or register your interest in a vehicle in a showroom or at an  event we, a manufacturer or third party have held 

when you place an order, purchase or book an appointment for a vehicle or for any  parts, goods or any other products or services 

where you make an appointment for a vehicle service or MOT 

when you apply for a loan, personal contract purchase or lease agreement from one of  our accredited finance providers to purchase your vehicle 

when you part exchange your vehicle or where you provide any service history relating  to your vehicle or provide any information to evidence that you are insured to drive a  vehicle 

when you register on the careers page of our website and when you apply for a role  with us 

by corresponding with us by phone, email, in person or any other means for any  reason

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Information that we receive from third parties 

We may also receive your personal information from third parties, such as: vehicle manufacturers

if you have requested a brochure, test drive, details about a vehicle or registered an  interest in a vehicle 

to provide vehicle support services or in the event of a safety or product recall 

if you exercise your data subject rights and we receive notification from the  manufacturer 

finance providers and brokers 

where you have engaged a third party broker to act on your behalf to administer the  purchase of a vehicle 

where we are provided with your personal information by our approved finance  providers to allow us to contact you during the term of your contract. For example, we  may contact you towards the end of your Personal Contract Purchase (PCP) contract  to discuss your options before and at the end of the contract 

Insurance providers 

when we are required to carry out repairs on your vehicle as part of a claim you have  made through your insurance 

Regulatory and supervisory bodies 

such as the Driver and Vehicle Licencing Agency (DVLA) where we need to confirm if  you hold a valid driving licence for the purposes of providing a courtesy or loan car or  a test drive 

Recruitment 

if you apply for a role with us through a recruitment agency or job board provider then  we will need your personal information for the purposes of assessing your application 

5 How we may process your personal data 

We will only process your data where the law allows. Your personal data will, most commonly,  be processed in the following circumstances: 

Where required to perform a contract with you. Where it is necessary to process your  personal data for the performance of a contract with you or in order to take steps at your  request before entering into a contract with you. 

Where there is a legal or regulatory obligation. Where we need to process your personal data  to comply with our legal obligations such as assisting the ICO, DVLA, DVSA, FCA, HMRC, the  police or any other public authority or criminal investigation body. We may also need to  process your personal data to identify you when you contact us or to verify the accuracy of the  data that we hold about you.

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Legitimate interest. We may process your personal data where it is in our legitimate interests  (or that of a third party) and those interests do not override your rights and freedoms. For  example, we may contact you to notify you about your vehicle’s servicing or MOT  requirements. 

Vital interests. Where it is necessary to process your personal data to protect your vital  interests or those of another person. For example, we may contact you to notify you about  safety or product recalls relating to your vehicle.  

Consent. We may rely on your consent to send you direct marketing communications. Details  on how you can change the way we contact you are set out in section 11. 

Please click here to view and/or download a table describing in more detail the ways in which  we may process your personal information and which of the legal means we rely on to do so. 

We will only use personal data for the purposes for which it was collected, unless we  reasonably consider that we need to use it for another reason and that reason is compatible  with the original purpose. Please contact us using the details set out in section 2 if you need  details about the specific legal ground on which we are relying to process your personal data.  

6 Cookies 

Cookies are small files of letters and numbers that we store on your browser or the hard drive  of your device. There are different types of cookies that we use for different purposes; however  generally speaking cookies help us to distinguish you from other users of our website, which  allows us to provide you a better experience and also allows us to improve our website. 

You can block cookies at any time by activating the setting on your browser that allows you to  refuse some or all cookies. However, if you do block cookies there may be parts of our website  that you will be unable to access or that will not function properly. 

We use the following types of cookies: 

Strictly necessary cookies.  

These are cookies that are essential for the operation of our website. They include, for example,  cookies that enable you to log into secure areas of our website, use a shopping cart or make use  of e-billing services.  

Analytical/performance cookies.  

They allow us to recognise and count the number of visitors and to see how visitors move  around our website when they are using it. This helps us to improve the way our website works,  for example, by ensuring that users are finding what they are looking for easily.  

Functionality cookies.  

These are used to recognise you when you come back to our website so that we can personalise  our content for you, greet you by name and remember your preferences (for example, your  region). 

If you require further information about the cookies we use, then please contact us using the  details provided in section 2. 

Third party services

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Please note that third parties (including, for example, advertising networks and providers of  external services like web traffic analysis services) may also use cookies, over which we have no  control. These cookies are likely to be analytical/performance cookies or targeting cookies 

We sometimes use cookies in its email communications, to personalise the email, track whether  the email has been opened or read, and whether the recipient has used any website links  contained in the email communication. This allows us to monitor and improve our email  communications and website. 

7 Subscribing and unsubscribing to our marketing 

If you have made an enquiry into our products or services, we will provide you with a clear  choice to consent to receiving marketing materials by giving you an opt-in to receiving such  communications. If you have provided your consent we may collect your contact details (name,  postal address and email address) and vehicle details (make and model) to provide you with  such communications. 

If you ever decide you want to change your marketing preferences or no longer wish to receive  our marketing communications, you can do so at any time by using the unsubscribe link  provided in the marketing communications email, or by using the contact details in section 2  above. If you do unsubscribe, please note that we will still keep your email in a separate secure  list so that we can make sure that you do not receive our marketing communications again in  the future.  

8 Your data and third parties 

We may share your personal data with carefully selected third parties in order to make certain  services available to you and we have explained those types of scenarios in the table in section  5.  

We only share the minimum amount of data required and our third party suppliers only have  rights to use your personal data for the purpose of fulfilling the service required from them.  

We use a large number of suppliers so we have not provided a full list in this Privacy Notice. We  can confirm that the categories of third party that we may share your personal data with in  order to provide our products and services include: 

Vehicle Manufacturers 

We share your personal data with the manufacturers listed below and a copy of their privacy  policy can be found by clicking on their name: 

Audi UK 

BMW Group UK 

Daimler Group (UK) Ltd (see privacy link for Mercedes-Benz and smart) Jaguar Land Rover 

MINI 

Porsche 

Volkswagen UK

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Volkswagen Commercial Vehicles 

We share data with the manufacturers for the following purposes: 

to fulfil your order for a vehicle 

for warranty, registration and safety/product recall purposes relating to your vehicle to diagnose and fix problems with your vehicle 

or, where you have provided consent, for marketing communications Finance Providers 

If your enquiry leads to the purchase of a vehicle with a finance agreement, we will disclose  your information to our selected finance partners. If you are accepted for finance, the finance  company with become the data controller for your information and we recommend that you  read their privacy policy to see how they will use your data. 

Service Plans 

If we provide you with a Service Plan quote we will disclose your information to our Service  Plan partners. If you decide to purchase a Service Plan from us then our partner will act as a  Data Processor on our behalf.  

Other Third Parties 

We may also provide your personal information to our insurance administrators, IT providers,  service, maintenance and repair providers, vehicle breakdown and recoveries providers,  accident and incident management providers, risk management and driving licence checking  providers, financial organisations, banks and credit brokers, credit reference agencies,  marketing agencies, the Inchcape group and legal, governmental and regulatory authorities. 

Some of our third party suppliers will be data controllers in their own right. If they are in  receipt of your personal data or they collect it from you directly they will provide you with a  copy of their individual privacy notices. 

9 Disclosure of personal information 

We will not usually disclose your personal information other than as already explained in Section 8 above. However, there may be circumstances where we need to share personal information  other than as anticipated. These include: 

where we are legally required to disclose the information. This includes sharing the  personal information with tax authorities and law enforcement agencies for the  purposes of the prevention and detection of crime 

where we need to disclose the personal information for the purpose of resolving a  complaint or in connection with any legal proceedings, or for the purpose of obtaining  legal advice, or the disclosure is otherwise necessary for the purposes of establishing,  exercising or defending legal rights 

disclosure is required to protect our interests, or someone else’s interests (for  example, to prevent fraud)

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disclosure is necessary to protect your vital interests (for example if you are unwell at  our premises, we may need to seek medical assistance) 

it is to a third party for the purposes of providing administrative or processing services  on our behalf. If such disclosure is required we will take steps to ensure that the third  party protects the personal information in the same way that we do and notify you of  any changes to this privacy notice 

to any prospective purchaser of our business assets or organisation Transferring Personal Data outside of the European Economic Area 

We do not routinely transfer your personal data outside of the European Economic Area (“EEA”)  and we use all reasonable endeavours to select suppliers who provider assurances that personal  data is stored and processed within the EEA. With any international cloud technology providers  however (such as Microsoft and Salesforce) there is small possibility that personal data that is  stored within the EEA is accessed outside of the EEA for technical support or account  assistance. We therefore ensure that where we use technology providers or similar suppliers  who potentially access personal data from outside of the EEA we ensure that we put in place  adequate measures to ensure the protection of such personal data (such as using the EU’s  model clauses or the US Privacy Shield framework). 

10 Keeping personal information secure 

We know that you provide your personal information in good faith and expect it to be looked after. This is why we take the security of your personal information seriously. This means that  we have taken steps internally in order to ensure that our systems adequately protect your  personal information. Inchcape UK is also Cyber Essentials accredited. 

11 Your rights 

You have a number of rights in respect of your personal information which we have explained  in a bit more detail below: If you would like more information about any of your rights, please  contact us on the details set outset out in section 2 above. 

The right to request correction of the personal data we hold about you. You can have any  incomplete or inaccurate data we hold about you corrected, although we may need to verify  the accuracy of any new information you provide. 

The right to withdraw your consent where we are relying on your consent to process your  personal data. If you would like to withdraw your consent to receiving any direct marketing,  you can do so at any time by using the unsubscribe link provided in the marketing  communications email. If you simply want to change your marketing preferences (for example,  the method of communication), you can do so by using the contact details in section 2 above.  

Where you have explicitly consented to us processing special categories of data, you can  withdraw consent to our processing the special categories of data at any time during the  application process. If you wish to withdraw consent, please do so by sending your request in  writing to our contact details below.  

The right to request access to your personal data. You can contact us at any time to ask  whether we process any personal data about you and to be provided with a copy of that data.  This will be provided free of charge. We may not provide you with a copy of some of this 

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information if it also concerns other individuals or we have another lawful reason to withhold  it. 

The right to request erasure of your personal data. You can ask us to delete or remove  personal data where there is no good reason for us continuing to process it. You also have the  right to request that we delete or remove your personal data where you have successfully  exercised your right to object to processing, where we have processed your personal data  unlawfully or where we are required to delete your data by operation of law. We may not  always be able to completely comply with your request where we have specific legal reasons  which will be notified to you. 

The right to object to processing of your personal data where we are relying on our legitimate  interest (or those of a third party) and there is something about your situation which makes  you want to object to processing on the grounds it impacts on your fundamental rights and  freedoms. You also have the right to object where we are processing your data for direct  marketing purposes. In some instances we may demonstrate that we have compelling  legitimate grounds to process your information which override your rights and freedoms.  

The right to transfer your personal data to you or another party. We will provide you or the  third party with your personal data in a structured and commonly used machine-readable  format. 

Exercising your rights. If you wish to exercise any of your rights then please contact us using  the details set out in section 2. You will not normally have to pay a fee to exercise your rights  but we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We  may also refuse to comply with your request. We endeavour to respond to all legitimate  

requests within one month. If we will need longer than a month to respond to your request  then we will let you know and keep you updated. 

12 How long will we keep your personal data? 

We will hold your personal data for no longer than is necessary for the purposes for which we  are processing it. When it is no longer required we will securely dispose of it. 

All electronic and hard copy files, relating solely to purchase information, will be destroyed  after 7 years. 

If we have anonymised or pseudonymised your personal data (so you can no longer be  identified by it) we may use or hold the information for longer periods without notice. 

13 Updating this privacy notice 

We keep our privacy notice under regular review in order to ensure that it properly reflects our  use of personal information. This privacy notice was last updated on 27 June 2019.

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How do we process personal data?  

The purpose of this document is to identify each of the ways in which we process our customer’s  personal data and the legal basis we rely on to do so. This information will be provided to customers  (via our privacy policy) and will enable Inchcape to put in place the appropriate policies and  procedures. 

Making a vehicle enquiry or negotiating to buy a vehicle 

Processing Activity 

Type of data 

Legal basis 

To respond to your enquiries and to fulfil your requests – for  example to send you a brochure or to provide details about a  vehicle 

Contact data /  

Audio data 

Contractual  

performance /  

Legitimate interest 

To email you a video presentation about a vehicle you have  enquired about 

Contact data 

Contractual  

performance /  

Legitimate interest 

To follow up on a request you have made through a third party  website – such as Autotrader or Car Wow – to enquire about a  vehicle we have advertised 

Contact data 

Legitimate interest 

To arrange a test drive where we have a legal obligation to check  you hold a valid driving licence and for insurance purposes and  compliance with the Road Traffic Act 

Contract data /  

Identity data 

Contractual  

performance /  

Legal or regulatory  obligation 

Photographic images and footage of you is collected via the  operation of CCTV when you come into our showrooms or visit  our dealerships. This is for security, crime prevention and  required for insurance purposes. 

Image data 

Legitimate interest 

Purchasing a vehicle 

Processing Activity 

Type of data 

Legal basis 

Completion of all mandatory sales documentation to purchase a  vehicle 

Contact data /  

Identity data /  

Vehicle data /  

Transaction data /  Family data if  

applicable

Contractual  

performance

Sharing your personal data with vehicle manufacturer systems to  allow vehicle ordering, in car systems setup, and activation of  services and products for the vehicle including warranty

Contact data /  

Vehicle data /  

Family data if  

applicable

Contractual  

performance

Administer the manufacturer’s complimentary insurance on your  behalf (if applicable)

Contact data /  

Family data if  

applicable

Contractual  

performance /  

Legal or regulatory  obligation

 

Registering and taxing the vehicle with the DVLA 

Contact data /  Vehicle data

Contractual  

performance /  

Legal or regulatory  obligation

To provide or manage any information, products or services you  have asked for specifically related to the purchase of your 

Contact data 

Contractual  

performance /  

Consent

 

vehicle – for example the purchase of an asset protection policy  or cosmetic repair product 

   

If you are part exchanging or selling your vehicle to our  dealership we will check your vehicle details via our third party  provider CAP-HPI before making an offer to buy the vehicle and  may use an appraisal tool provided by BCA 

Vehicle data 

Contractual  

performance  

/ Legal or  

regulatory  

obligation

To send you a customer survey following your vehicle purchase  to gain your feedback about our products and services provided 

Contact data 

Legitimate  

Interest

Purchasing a vehicle with Finance 

Processing Activity 

Type of data 

Legal basis 

To administer and arrange finance for you to purchase or lease a  vehicle

Contact data /  

Vehicle data /  

Identity data /  

Financial data

Legal or regulatory  obligation /  

Legitimate interest

Completion of documents required to comply with the FCA  guidelines when administering finance on your behalf

Contact data /  

Vehicle data /  

Identity data /  

Financial data

Legal or regulatory  obligation

To enter your personal details into the finance provider’s system  so the finance provider can conduct a credit check and  affordability assessment on you before making a decision  whether to offer you finance to fund your vehicle

Contact data /  

Vehicle data / 

Identity data /  

Financial data

Contractual  

performance /  

Consent

If your application for finance is declined by the finance provider,  we will advise you of this before sending your personal  information to another lender for consideration. We will always  seek your consent before passing your application to other  approved finance providers or credit brokers 

Contact data /  

Vehicle data /  

Identity data /  

Financial data

Consent

To contact you where you may be suitable to purchase a  subsequent vehicle with finance, for a contract renewal, at the  end of your contract or in relation to the purchase of a new  vehicle 

Contact data /  

Vehicle data /  

Identity data /  

Financial data

Legitimate Interest

 

Vehicle maintenance, repairs and servicing 

Processing Activity 

Type of data 

Legal basis 

To contact you to book an appointment to bring your vehicle  into the dealership which falls under your service contract or  service plan for your vehicle 

Contact data /  

Vehicle data /  

Audio data

Contractual  

performance

To register your vehicle with service plans administered by the  vehicle manufacturer or a third party provider. 

Contact data /  

Vehicle data /  

Audio data

Contractual  

performance

To collect or deliver your vehicle outside our dealership for  example to collect your vehicle from your home or work address  to undertake service works on the vehicle. This service maybe  outsourced to an approved third party vehicle delivery company 

Contact data /  

Vehicle data

Contractual  

performance

 

Arranging a courtesy car or loan/rental car. If we agree to  provide a courtesy or loan/rental vehicle to you for the duration  of the works on your vehicle then you will be asked to provide a  copy of your driving licence for insurance purposes and to  ensure you hold a valid driving licence. If we are going to provide  a loan/rental vehicle then we will need to provide your details to  the third party that will provide that vehicle. If you incur any  speeding, parking or other motoring offences when using the  vehicle we will forward your contact data to the third party  enforcing the penalties.

Contact data /  

Vehicle data /  

Identity data

Contractual  

performance /  

legal or regulatory  obligation

We will contact you in relation to all on-going servicing, repairs  and maintenance of your vehicle, including manufacturer  warranty claims 

Contact data /  

Vehicle data /  

Audio data

Contractual  

performance /  

Legitimate  

interest

Rectification works to your vehicle as part of an insurance claim.  Your insurance provider may request your vehicle is repaired by  one of our approved body shops and they will share your  personal information with Inchcape for this purpose 

Contact data / 

Vehicle data

Contractual  

performance /  

Legitimate  

interest

We may capture your vehicle registration number when you  drive onto our dealership premises using ANPR to recognise you  in relation to your service booking 

Contact data  

/ Vehicle data /  Image data

Contractual  

performance /  

Legitimate  

interest

Breakdown assistance, your personal details are provided by the  breakdown provider to Inchcape to complete the repairs 

Contact data /  

Vehicle data

Contractual  

performance /  

Legitimate  

interest

We will contact you to notify you when your vehicle is due for  servicing or MOT as part of our ongoing service to you. The legal  responsibility for maintaining the vehicle in line with the  manufacturer’s guidelines is with you. 

Contact data 

Legitimate  

interest

 

To contact you if there is a safety or product recall notice issued  by the manufacturer to arrange rectification works at our  authorised dealership. 

Contact data /  Vehicle data

Vital interest

We may contact you with other communications relating to  manufacturer recommendation for maintenance of your vehicle,  vehicle health checks or other similar services 

Contact data /  Vehicle data

Legitimate  

interest

Processing necessary for us to promote our business and engage with our customers 

Processing Activity 

Type of data 

Legal basis 

If you are an existing or new customer to Inchcape we will send  you promotional marketing information including invitations to  events in our dealerships and offers from time to time if you  have purchased a product or service from us. You have the right  to object to us sending you this information at any time. Please  see section 11 in this privacy notice for further detail about your  rights. 

Contact data 

Consent 

If you do not have a previous relationship with Inchcape or have  never negotiated to buy a vehicle or purchased any of our  products or services we will only send you marketing  communications if you have opted in to receive these  communications 

Contact data 

Consent

 

To contact you with targeted advertising delivered online  through social media and other platforms operated by other  companies, unless you object. You may receive advertising based  on information about you that we have provided to the platform  or because, at our request, the platform has identified you as  having similar attributes to the individuals whose details it has  received from us. To find out more, please refer to the  information provided in the help pages of the platforms on  which you receive advertising from us. 

Social Network  

data / Website  

data

Legitimate interest

To identify and record when you have received, opened or  engaged with our website or electronic communications 

Contact data /  

Social Network  

data / Website  

data

Legitimate interest

To contact you in relation to additional products and services,  including those offered by third parties, that may be related to  your vehicle such as asset protection and extended warranty  protection plans. 

Contract data /  vehicle data 

Legitimate interest

To administer competitions and promotions that you enter with  us from time to time and to distribute prizes 

Contact data 

Consent

 

To undertake market analysis and research (including contacting  you with customer surveys) so that we can better understand  you as a customer and provide tailored offers, products and  services that we think you will be interested in. 

Contact data 

Legitimate interest

To work with third parties to help us with our advertising and  marketing such as helping us to understand how well our  advertising works, who may benefit from our, and our third party  partners’, products and services and also to reach people who  may be interested in our, and our third party partners’, products  and services.

Contract data /  vehicle data 

Legitimate interest 

We may take photographic images of you when you collect your  new vehicle from the dealership or record video footage during  dealership events with your consent to promote our business via  social media channels or via our websites 

Image data 

Consent

Processing necessary for our business to operate on a daily basis and to fulfil data protection laws 

Processing Activity 

Type of data 

Legal basis 

For general administration including managing your queries,  complaints, or claims and liaising with our advisors and industry  associations for the resolution of your complaints or claims 

Contact data 

Contractual  

performance/  

Legitimate  

interest

Processing necessary for us to operate the administrative and  technical aspects of our business efficiently and effectively 

Contact data 

Contractual  

performance

For network and information security purposes i.e. in order for  us to take steps to protect your personal data against loss,  damage, theft or unauthorised access 

Contact data 

Legal or regulatory  obligation

To comply with a request from you in connection with the  exercise of your rights (for example where you have asked us not  to contact you for marketing purposes, we will keep a record of  this on our suppression lists in order to be able to comply with  your request) 

All types of data  Depending on the  request

Legal or regulatory  obligation

     

To inform you of updates to our terms and conditions and  policies 

Contact data 

Legal or regulatory  Obligation

To inform you of changes to our business, for example the  opening or closing of dealership sites 

Contact Data 

Legitimate interest 

 

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