Privacy Notice

Jardine Motors Group takes its obligations with regard to data protection seriously. As such, we are providing this notice (“Privacy Notice”) to you so that you are provided with information about how Jardine Motors Group collects and processes your personal data in accordance with the General Data Protection Regulation (“GDPR”). Please read this Privacy Notice, as it contains important information that you need to know.

Jardine Motors Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

Jardine Motors Group includes Lancaster plc (a company registered in England and Wales with company number 1538570) along with its subsidiaries Lancaster Motor Company Limited, Lancaster Cars Limited,

Lancaster Luxury Vehicles Limited, Lancaster Specialist Cars Limited and Lancaster Sports Cars Limited (the “Operating Companies”) all of whom share a registered office at 770 The Crescent, Colchester, Essex, CO4 9YQ. Each of the subsidiaries, with assistance from their parent, operate one or more franchises to market and sell certain branded vehicles with related accessories, parts and services. Jardine Motors Group is managed as a single entity with processes and management operating seamlessly across the group. Please see our website at www. jardinemotors.co.uk for an up to date list of companies that fall within Jardine Motors Group.

Please note that references to we, us or our means the members of the Jardine Motors Group that process your personal information, being any Jardine Motors Group company or dealership that supplies details about, or provides, vehicles, accessories, parts and/or related services to you, and Lancaster plc. In this Privacy Notice, references to you mean the person whose personal information we collect, use and process. This includes anyone who contacts us in connection with the products and services we provide or otherwise interacts with us about them, including, for example, at any of our dealerships. This Privacy Notice should be read alongside other information we provide to you about our use of your personal details, such as through our Website Privacy Policy if you deal with us through our website.

1. What do we collect and process?

In order for Jardine Motors Group to provide its products (including vehicles and parts) as well as its services to you, it is necessary for us to collect, maintain and process personal data about prospective and/or existing customers. “Personal Data” is information which relates to you and (either on its own or in combination with other information

Jardine Motors Group holds) allows Jardine Motors Group to identify an individual prospective and/or existing customer and thus enable us to provide our products and services, or details of them, to you.

The Personal Data which we process may include the following:

 

  • your full name and contact information (address, city, post code, email address and telephone number);
  • your work address and contact details;
  • details of your enquiry or interest or preference(s) about our products or services, such as possible planned purchase or lease date, vehicle(s) brand, make and/or model, or vehicle requirements;
  • records of calls, emails, correspondence with you and of visits to us in relation to such enquiries, negotiations, resultant sales and/or supplies;
  • the registration number, brand, make, model of your vehicle, and GPS data;
  • your image, actions and location if you are recorded on CCTV which we operate on and around our sites;
  • in the event that you purchase a vehicle and/or services, information including registration number, brand, make, model, model year, selling dealership, servicing dealership, date of purchase, lease or service history;
  • in the event that you purchase vehicle parts, what they are, for which brand, make and model;
  • time and date of any purchases or sales by you, including any prices and payment (including bank account and/or credit card) details, data collected on finance applications;
  • with your consent, credit check details and proof of identity/valid driving licence information, such as passport/driving licence and utility bill details;
  • demographic information (including your age range, employment status, marital status and household composition);
  • details about any marketing consents and marketing preferences; and
  • customer feedback and survey results.

 

Personal Data will primarily be collected from you directly on a voluntary basis. However, some Personal Data may, where lawful to do so, be collected by Jardine Motors Group from (and/or used by) third parties (e.g. credit rating agencies from whom you have agreed prior to any check being undertaken that we may obtain your personal information, including your credit history or publically available information about you).

Please note that you are under no obligation to provide Jardine Motors Group with your Personal Data, but not providing such data when requested could prevent Jardine Motors Group from being able to help you, from providing information or products and/or services to you as requested and from fulfilling your order.

We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we usually collect any information about criminal convictions and offences, with the exception of any driving or motoring offences revealed from a check of your driving licence. We are required to check your driving licence (including carrying out appropriate checks with DVLA) to verify your eligibility to legally drive any of our vehicles and to meet the requirements of our insurers (as amended from time to time).

For customers with a disability who are seeking to purchase a vehicle supplied by us with the benefit of zero rated VAT relief (or any other tax benefits, as amended from time to time by law), we may require proof of your eligibility (including appropriate medical information) to process the benefit(s) or otherwise to process the transaction in accordance with the scheme rules, any relevant guidance and recognised best practice.

 

  • with your consent, credit check details and proof of identity/valid driving licence information, such as passport/driving licence and utility bill details;
  • demographic information (including your age range, employment status, marital status and household composition);
  • details about any marketing consents and marketing preferences; and
  • customer feedback and survey results.

 

Personal Data will primarily be collected from you directly on a voluntary basis. However, some Personal Data may, where lawful to do so, be collected by Jardine Motors Group from (and/or used by) third parties (e.g. credit rating agencies from whom you have agreed prior to any check being undertaken that we may obtain your personal information, including your credit history or publically available information about you).

Please note that you are under no obligation to provide Jardine Motors Group with your Personal Data, but not providing such data when requested could prevent Jardine Motors Group from being able to help you, from providing information or products and/or services to you as requested and from fulfilling your order.

We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we usually collect any information about criminal convictions and offences, with the exception of any driving or motoring offences revealed from a check of your driving licence. We are required to check your driving licence (including carrying out appropriate checks with DVLA) to verify your eligibility to legally drive any of our vehicles and to meet the requirements of our insurers (as amended from time to time).

For customers with a disability who are seeking to purchase a vehicle supplied by us with the benefit of zero rated VAT relief (or any other tax benefits, as amended from time to time by law), we may require proof of your eligibility (including appropriate medical information) to process the benefit(s) or otherwise to process the transaction in accordance with the scheme rules, any relevant guidance and recognised best practice.

2. Systems used to process data

Jardine Motors Group gathers information directly from you and also via our websites and other technical systems. These may include, for example, our:

 

  • computer networks and connections;
  • CCTV and access control systems;
  • communications systems;
  • remote access systems;
  • email and instant messaging systems;
  • intranet and internet facilities; and
  • telephones, voicemail, mobile phone records.

 

Some limited personal data may be collected from monitoring devices and systems such as closed circuit TV within our dealerships and premises. This will be retained in line with our retention policy.

3. Why and for what purposes do we need your Personal Data?

Jardine Motors Group processes your Personal Data about you for a number of purposes, including:

 

  • to respond and/or deal with your requests or enquiries;
  • where we need to perform the contract we have entered with you;
  • where we need to comply with a legal or regulatory obligation;
  • to make an appointment with you to visit one of our dealerships, or to arrange a test drive;
  • for internal record keeping (including customer enquiry, deal files, accounting and complaint files);
  • for vehicle number plate recognition that alerts us when you arrive at some of our dealerships and allows us to improve on site security and customer service;
  • to provide our products and services to you as requested or agreed;
  • to help us review, develop and improve the products and services we offer, for example through surveys, research, analysis and planning;
  • to provide you with details of our products and/or services from time to time, such as relevant offers, including by direct marketing by post or as otherwise agreed with you, such as by telephone, email, or otherwise;
  • to communicate with you accordingly, including to provide you with customer and vehicle support, such as notifying you about changes to our products and services, any issues with them, product recall, and to otherwise communicate with you, for example to respond to queries from you;
  • to process and retain personal data relating to your credit/debit card (or bank account details) and order details to enable the fulfilment of your order, financial applications and to deal with any payments, sales proceeds, or refunds of payment;
  • to remind you about important dates, such as service due dates and warranty expiry dates;
  • to contact you from time to time to ensure your details on record are correct and up to date and to ensure we have your up to date preferences for marketing and contact; 
  • to depersonalize, pseudonymise or fully anonymise and/or aggregate your data to reduce privacy intrusion but facilitate our use of the data for analysis and research, to better understand our business and customer base and their needs and to improve our products and services and business;
  • where necessary as part of any restructuring of Jardine Motors Group or sale of any Jardine Motors Group company, business or assets; and
  • to carry out security checks to protect against fraudulent transactions at or following any purchase or order you make to prevent and detect criminal activities. For example, we may undertake verification checks to identify any discrepancies with your payment details for fraud prevention and staff training purposes.

 

This list is not exhaustive and may be updated from time to time.

Jardine Motors Group will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If Jardine Motors Group need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at Customer

Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear NE7 7EG.

Subject to applicable laws, Jardine Motors Group may also process Personal Data for other legitimate business purposes including management analysis, audits, financial forecasts, business planning and transactions, ensuring its compliance with applicable laws, regulatory requirements and Jardine Motors Group policies, and dealing with complaints, legal claims, record retention obligations and other related administrative activities. Jardine Motors Group may also use Personal Data to establish or exercise its legal rights and to comply with law enforcement or other government agency requests or court orders.

We do not ‘trade’ in your personal data and will not sell or rent your details.

4. Who will your Personal Data be shared with?

Personal Data will be shared and transferred between members of the Jardine Motors Group for any of the purposes set out in this Privacy Notice (or for such other purposes as are notified to you by Jardine Motors Group from time to time). Given the structure of Jardine Motors Group, your Personal Data may be transferred to Lancaster plc as the parent company of each of the Operating Companies. There is always a good reason for our sharing, such as where you contact one of our companies or dealerships but are interested in a different vehicle, when we may pass on your details to the relevant company and closest dealership to help you.

Jardine Motors Group aims to ensure high quality and secure Personal Data use. To facilitate this, Jardine Motors Group has in place an Intra Group Agreement to identify and deal with data protection and other relevant legal requirements involved in the sharing, transfer and other processing of customer Personal Data between the Jardine Motors Group companies. For further details of Jardine Motors Group, please visit our website www.jardinemotors.co.uk.

Jardine Motors Group is authorised by a number of manufacturers to market, sell and supply specific branded vehicles, accessories, parts and related services, subject to requirements imposed by the manufacturers. If you express an interest in a specific brand, especially in a particular make and model, or if the interest is in a specific branded vehicle, make and model (such as wishing to place a factory order for a

new car), Jardine Motors Group may share your details with the relevant manufacturer to check vehicle availability, place an order, confirm delivery and timing, ensure warranty registration and/or service cover, deal with warranty claims and service issues, or deal with recall or comparable warnings and requirements.

Your personal information may also be made available to third parties (within or outside Jardine Motors Group) providing relevant services under contract to the Jardine Motors Group, such as marketing agencies, auditors and compliance managers, insurers and IT hosting, administration and IT maintenance providers. These companies may use information about you to perform their functions on our behalf in accordance with the services we have requested and contract terms

imposed. We may also disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes.

Jardine Motors Group does notknowingly collect personal datarelating to children under the ageof 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us at Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear NE7 7EG. Jardine Motors Group will ask you to prove your relationship to the child, but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.

In the event that we negotiate to and/or sell any of our Jardine Motors Group companies, businesses (in whole or part) or assets, we may share your details with the proposed/actual buyer and their relevant accountants (including funders, accountants, auditors and lawyers).

Your personal information may be transferred to, and stored, and otherwise processed in, one or more countries outside of the European Economic Area (“EEA”) where manufacturers and/or service providers are based there and/or provide services from there. Jardine Motors Group is committed to ensuring that adequate safeguards are in place when transferring Personal Data outside the EEA, both between Jardine Motors Group companies and externally.

Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

 

Please contact us at Customer Services, c/o Lexus Newcastle,

22 Benton Road, Newcastle, Tyne & Wear NE7 7EG if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5. What choices does Jardine Motors Group offer you with regard to direct marketing?

Jardine Motors Group may wish to provide you with information about products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post or SMS.

We will obtain your consent to such marketing and details about your marketing preferences and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.

The relevant vehicle manufacturer will also want to send you marketing information in accordance with their privacy policy and marketing information and consents you provide to them. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where you have opted in, third-party service providers or manufacturers may use your personal data for their marketing purposes as notified to you at the time your personal data is collected and subject to you providing your consent and in line with their direct marketing requirements.

You may opt-out of direct marketing activities from Jardine Motors Group by contacting us as follows:

 

  • using the unsubscribe or opt out links in marketing communications which we send to you;
  • e mailing our central data services department at centraldataservices@jardinemotors.co.uk; or
  • writing to us at Customer Services, c/o Lexus Newcastle,

 

22 Benton Road, Newcastle, Tyne & Wear NE7 7EG.

This will allow you to opt out of marketing, telephone and email communications and/or to change previously submitted preferences. You can also call 0800 012 5050 to opt out of direct mail communications, as well as telephone and email communications, and/or to change previously submitted opt-out preferences.

6. What rights do you have to review and amend personal information?

You have the right to:

 

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information held by Jardine Motors Group. We have a template form for making such a request which you can obtain from Customer Services, c/o Lexus Newcastle,

 

22 Benton Road, Newcastle, Tyne & Wear NE7 7EG.

 

  • Request correction of the personal information that Jardine Motors Group holds about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask Jardine Motors Group to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask Jardine Motors Group to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we, the Jardine Motors Group, are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where Jardine Motors Group are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask the Jardine Motors Group to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • You have the right to lodge a complaint to the Information Commissioner’s Office at https://ico.org.uk/ if you believe that Jardine Motors Group have not complied with the requirement of the GDPR with regard to your personal data. 

 

If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear NE7 7EG.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights within this clause). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Further to any requests made under this section, we will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within the one-month original timeframe and keep you updated. In any event, we will provide a response within three months of receipt of the valid original request.

7. Keeping you informed

Jardine Motors Group may keep your details on record for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available

from Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear NE7 7EG. To determine the appropriate retention period for personal data, Jardine Motors Group considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances Jardine Motors Group may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (such as the Information Commissioner’s Office) of a breach where we are legally required to do so.

9. Changes to this Policy

Jardine Motors Group reserves the right to update this Privacy Notice at any time in order to reflect changes in the law and/or its privacy practices.

If required to do so by law, Jardine Motors Group will provide with you a new and/or updated Privacy Notice detailing how the use of your Personal Data is changing. If necessary, we will obtain your consent for the further Processing.

If you have any questions about this Privacy Notice, please contact us at Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear NE7 7EG.