ADAMS MOREY LIMITED PRIVACY NOTICE

INTRODUCTION AND DEFINITIONS

Adams Morey Limited (“we”, “our” and “us”) is committed to protecting and respecting your privacy. This notice (along with any contract you have with us) tells you how we process your personal data.

If you have questions about correcting or deleting your personal data please refer to section 8 below.

References in this notice to “data protection law” mean (as applicable) the Data Protection Act 2018, the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom from time to time.

References in this notice to “data or “information” include “sensitive personal data” and “special categories of data” (as defined under data protection law) where applicable.

1.      OUR DETAILS

1.1          The data controller with conduct of your personal information is Adams Morey Limited (company number  00506189) of The Causeway, Redbridge, Southampton, Hants, SO15 0DR.

1.2         Our data protection officer is James Wilkes. You can contact us at [email protected]

2.     WHAT INFORMATION ABOUT YOU DO WE COLLECT AND PROCESS?

2.1        Information you give us, or which we collect from you. This information may include personal data. Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed. The information we collect, use and hold may vary depending on which service you are using. The categories of information we use may include:

  1.  Identity and Contact Data such as names, addresses, e-mail addresses and phone numbers, dates of   birth, gender, marital status, national insurance number. If you contact us in your capacity as a representative of the organisation for which you work, for example if you raise a trade enquiry, then we may take your job title and role.
  2.  Driving Licence Data such as a copy of your driving licence or driving licence number.
  3.  Financial Data such as your financial and credit card information.
  4.  Technical Data including internet protocol (IP) address, login information, access times, browser type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our products and services.
  5.  Vehicle Information (including registration number, VIN, service reminders, mileage and warranty repair information) the time and date you used our services, and information within any correspondence with us (which may include Identity and Contact Data).
  6. Marketing and Communications Data including preferences in receiving marketing from us, and any selected partners from time to time, and your communication preferences

2.2        We collect this from you when you deal with us at one of our centres or if you provide it to us over the phone or by email or send an enquiry via our website, or if you request marketing information at a trade show or similar event.

3.     PURPOSES FOR, AND GROUNDS UNDER WHICH WE PROCESS YOU INFORMATION                   

We will only use your personal data when the law allows us to. The information below explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Sales and enquiries

We may process your Identity and Contact Data, and in some cases your Financial Data and Driving Licence Data to provide our products and services in accordance with any contract you have entered into with us, and to deal with your enquiries and requests. We do this on the grounds that the processing is necessary for the performance of the contract. This includes where you have instructed us to take some pre-contractual steps prior to us formalising a contract.

Dealing with warranty repairs

We may process your Identity and Contact Data, and Vehicle Information to deal with warranty repairs where the processing is necessary to meet our repair obligations under a contract between us, or the organisation you represent, or otherwise where it is in our legitimate interests in ensuring that we properly service vehicles provided.

Account management

For customer account management purposes we may also process your Identity and Contact Data example to contact you for reasons relating to products and services you, or the organisation you represent, have purchased from us or that you have enquired about, or for sending service or mileage reminders. We do this where it is necessary for our legitimate interests to ensure that the vehicles and service we provide are properly managed.

Marketing and promotions

From time to time, to inform you of, or provide you with information about our products and services, including changes to our services, we may process your Identity and Contact Data and Marketing and Communications Data. We do this where you have requested information from us, or where you have given us your consent to receive marketing information, having opted to be added to our mailing list. We may also do this in some cases where you or the organisation you represent have purchased services or goods from us.

Surveys

Your Identity and Contact Data and Marketing and Communications Data may be processed to invite you to participate in voluntary surveys about our products and services. We do this on the basis that it is in our legitimate interests in improving the products and services we can offer you.

Financing

Where relevant, we will also use Contact Data and Financial Data to arrange vehicle finance arrangements. Any such arrangements will be explained in more detail by a member of our team. We process data in this way on the basis that it is necessary for the relevant contractual arrangements which you will enter into with the finance company and therefore this use of data forms part of that initial arrangement in you taking steps with a view to entering into a finance arrangement with the finance company. The finance company will have its own data policies and statements which you should read.

Occasional processing

From time to time, where it is necessary to do so, we may also process any of the categories of personal data listed at 2.1:

  1. in connection with any ongoing or prospective legal proceedings;
  2. to the extent that we are required to do so to keep records, and comply with our legal obligations, such as in relation to tax and accounting; and
  3. in order to establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention.

Please note that we may process your personal data for these purposes without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Administration of our website

Like most other website operators, we collect your Technical Data. This is non-personally identifying information of the sort that web browsers and servers typically make available. We use such information to ensure that content from our site is presented in the most effective manner for you and for your device and to continually improve our website. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving our website and our services.

Information received by us

We may receive information about you from the manufacturer of your vehicle. We process information we receive where it is necessary to do so, as it is in our legitimate interests to ensure that we provide a proper and informed standard of service to you, or the organisation you represent.

4.     COLLECTION OF SPECIAL CATEGORIES OF DATA

We might in some cases, collect special categories of data from you, for example if you give us information about your health or a disability. We may need to collect this type of data from you to understand your vehicle needs or to put in place necessary reasonable adjustments that may be required to our services. We will only process special categories of data in this way on the basis that you have given your express consent to us to process it. We will apply special security measures to restrict access to any special categories of data we collect and store.

5.      CHANGE OF PURPOSES

We will only use your personal data for the purposes for which we collected or received it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6.     DURATION AND FURTHER PROCESSING

6.1          We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

6.2       Generally speaking, we retain your information for the following periods of time:

  1.  if you are on our marketing database, until you indicate that you no longer wish to hear from us; or
  2.  if you are a supplier or customer (or you work for one of our suppliers or customers) for the duration of our contract with you (or the person you work for) and for a period of seven years after the end of  the contract to which the personal data relates.

6.3    If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

7.     WHO IS YOUR INFORMATION  SHARED WITH?

7.1 In order to achieve the purposes set out in section 3 above, we may share your data with the following people or group of people:

  1.  We may share your name and address with the manufacturer of your vehicle where this is required – in connection with a warranty claim for example.
  2.  Our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. We control what our IT providers can access and they are subject to strict obligations of confidentiality.
  3.  We may provide personal data to our legal advisers or other professional advisers, if necessary to defend claims, protect our rights, or receive advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.
  4.   If the situation should ever arise that we sell our business, we may share personal data with potential purchasers of our business, subject to those persons entering into strict confidentiality obligations with us and only to the extent permissible under data protection law.

7.2  To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

8.      YOUR RIGHTS

8.1     Under data protection law, under certain circumstances, you have the following rights in relation to your  personal data:

  1.  if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by notifying us using the details set out in section 13 below. The lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent;
  2.  the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in section 9, below;
  3.  the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise the right at any time by contacting us using the details set out in section 13, below;
  4.  the right to object to decisions being made about you by automated means. We will inform you if your information is subject to automated processing. We do not make automated decisions about you   based on your information;
  5.  the right to object to us processing your personal information, in certain other situations, or the   suspend processing for certain purposes;
  6.  the right, in certain circumstances, to have your information rectified, blocked, erased destroyed if it is   inaccurate;
  7.  the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law; and
  8. in certain circumstances, the right to request the information we hold on you in a machine-readable format so that you can transfer it to other services. This right is called ‘data portability’. Additional details on how to exercise this right are set out in section 9, below

8.2       You also have the general right to complain to us, if you have any concerns about how we hold and process your information. Our contact details are set out in section 13, below.

8.3       You also have the right to make a complaint to the Information Commissioner’s Office (ICO) which is the    UK supervisory authority for data protection issues. The ICO’s website is www.ico.org.uk. We would however, like the opportunity to assist you with any concerns before you approach the ICO, so please contact us in the first instance using the details below.

8.4        For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the ICO (www.ico.org.uk).

9.     ACCESS TO INFORMATION

9.1       Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you.

9.2       You will not have to pay a fee unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We will also be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous.

9.3       in certain circumstances, you will be entitled to receive your personal data in a structured, commonly used machine-readable form.

10.     COOKIES

10.1     Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

10.2     Visitors to our site who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our site. This will mean that some features of our site may not function properly without the aid of cookies.

10.3     More information is available in our separate Cookies Policy on our website.

11.     DATA SECURITY

We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our site or otherwise to our servers (such as by email). Any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

12.     CHANGES TO OUR PRIVACY NOTICE

This notice was last updated in July 2019. Any material changes we may make to our privacy notice in the future will be uploaded to our website and if the change is significant, we will send you the updated notice by email. Please check back frequently to see any updates or changes to our privacy notice.

13.     HOW TO CONTACT US

For the purposes of this website and the information collected through it, Adams Morey is a data controller and is responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us, using the following details:

Contact: DataCo International UK Limited
Address: c/o One Peak Partners, 41 Great Pulteney Street 2nd floor, London W1F 9NZ, United Kingdom
Email: [email protected]
Tel: +44 20 3318 17 18

ADAMS MOREY LIMITED – PRIVACY NOTICE