1.1 This notice covers all Jardine Motors Group UK websites, apps and services including but not limited to:
1.1.2 news.jardinemotors.co.uk; and
collectively referred to as the “Website”.
1.3 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 notice.
1.4 Lancaster plc operates the Website for itself and its subsidiary operating companies including Lancaster Motor Company Limited, Lancaster Cars Limited, Lancaster Luxury Vehicles Limited, Lancaster Specialist Cars Limited and Lancaster Sports Cars Limited (the “Operating Companies”).Details of the Operating Companies can be found on the website www.jardinemotors.co.uk and all share a registered office at 770 The Crescent, Colchester,Business Park, Colchester, Essex, CO4 9YQ, together being the Jardine Motors Group of companies (“Jardine Motors Group”).
1.5 In this Policy, references to we, us or our means the members of Jardine Motors Group that process your personal information including: (1) any Jardine Motors Group dealership that supplies details about, or provides, vehicles, accessories, parts and/or related services to you and (2) Lancaster plc.
1.6 Lancaster plc is the direct parent company of the Operating Companies with trade and assets relating to different franchises sitting in separate legal entities.Jardine Motors Group is managed as a single entity with processes and management operating seamlessly across the group.Jardine Motors Group UK Limited is the overall UK parent company.
1.7 In this Policy, any reference to you means 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 through our Website.
1.8 This Policy explains how the Jardine Motors Group collects, uses and discloses personal information about you when you visit the Website and when you contact Jardine Motors Group, whether by e-mail, post or telephone, or visiting us in person after using the “contact us” options or completing a form on the Website.The information you provide to us through the Website will initially be collected by Jardine Motors Group and may be shared within the other members of our group for the purpose(s) described below.
1.9 This Policy explains our use of your “Personal Data” which is information which relates to you and (either on its own or in combination with other information we hold) allows us to identify you as an individual prospective and/or existing customer or user of our Website and thus enables us to provide our products and services, or details of them, to you.
2. Who is responsible for your personal information?
2.1 In respect of this Website, the data controllers who use Personal Data obtained through your visit to the Website are:
2.1.1 Lancaster plc; and
2.1.2 to the extent you use the Website contact facilities to directly contact, or request contact by, one of our specific dealerships and/or locations, the Operating Company within Jardine Motors Group operating that dealership and/or site location, details of which can be obtained www.jardinemotors.co.uk.
2.2 As described below, your personal information may be shared with other members of the Jardine Motors Group that may receive and process your personal information as a data controller in their own right.
3. What type of information does the Jardine Motors Group collect and why?
3.1 When you visit our Website, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave.The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests.This may allow us to find out which parts of the Website are popular or need changing or to show you products and services of relevance to you, either on the Jardine Motors Group website or through online advertising on Google, Facebook or other websites.These details are in addition to Personal Data collected below but unless you register an account with us and use that on our website your Website usage details are not linked to other Personal Data we may collect about you.
3.3 The Website allows you to interact with Jardine Motors Group in many ways, including raising customer services enquiries, emailing us if you have a question, any feedback, suggestions for us to consider as well as interacting with us through our social media accounts including Facebook, Twitter and live chat.
3.4 We would be happy to interact with you in the ways described above.You can choose to provide us with some personal information described in more detail below.We will then collect that information for our own use and for the purposes described in this Policy.
4. What type of personal information does Jardine Motors Group collect?
4.1 Where you choose to provide personal details to us, we may collect the following personal information from you:
- your full name and contact information (address, city, post code, email address and telephone number);
- your main 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 emails and correspondence with you in relation to such enquiries, negotiations, resultants sales and/or supplies your contact and marketing preferences;
- the registration number, brand, make, model and mileage of your current vehicle;
- 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;
- if you take a survey or interact with us in various other ways (including information about subjects that may interest you);
- details about any marketing consents and marketing preferences;
- customer feedback and survey results;
- information you voluntarily submit to us (including through the Website) from time to time as part of user generated content (or through other means);
- information necessary for legal compliance; and/or
- information you choose to share from the Website through other social media outlets where similarly accessed through the Website (including Facebook and Twitter).
4.2 This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties.We may also collect personal information about you from your use of other Jardine Motors Group websites or services.In addition, we may combine your Personal Data with other data held by third parties (such as vehicle and value data) to allow us to provide vehicle valuation services.We may also buy in data for marketing purposes.
5. Systems used to process data
5.1 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.
5.2 Some limited personal data may be collected from monitoring devices and systems such as closed circuit TV.
5.3 Our website is powered by G-Forces Web Management Limited (“GForces”), our third party web services provider. We have a written agreement in place with GForces to ensure that data is processed in accordance with applicable data privacy laws and is kept secure.
6. How does Jardine Motor Group use information about you?
6.1 Jardine Motor Group may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Website or with our services.For example, we may use information about you for the following purposes:
- providing our products and services to you;
- making an appointment with you to visit one of our dealerships;
- to respond and/or deal with your request or enquiry through the Website;
- to administer the Website;
- for internal record keeping (including customer enquiry, deal files, accounting and complaint files);
- to provide a valuation of your car through the Website;
- to contact you by e-mail or phone for any of the above reasons;
- to provide you with information at your request, or as a result of searches undertaken using the Website;
- undertaking customer service surveys to ensure we continually improve our service(s) to you;
- helping us review, develop and improve the products and services we offer, for example through research, analysis and planning;
- 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, such as product recall, and to otherwise communicate with you, for example to respond to queries from you;
- processing and retaining Personal Data relating to your credit/debit card and order details to enable the fulfilment of your order, financial applications and to deal with any queries or refunds of payment;
- carrying 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;
- responding to and addressing any claims made against us;
- using cookies and traffic data as set out in Clause 3 above;
- to carry out direct marketing to you using the details you have provided (postal address, email and/or telephone calls, messages and/or texts) for similar goods and services;
- to provide you with details of our products and/or services from time to time, including relevant offers, including by direct marketing by post or as otherwise agreed with you, such as by telephone, email, or otherwise;
- 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 depersonalise, 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 Jardine Motors Group company, business or assets;
- for compliance with legal, regulatory and other good governance obligations; and
- for the management and administration of insurance claims.
6.2 This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.Some of the personal information that Jardine Motors Group maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.
6.3 The legal basis for this processing is consent, legitimate interests, namely monitoring and improving our website and services, dealing with your enquiry or purchase and/or such processing being necessary to comply with our legal (and regulatory) requirements.
6.4 Jardine Motors Group may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to monitor and improve Website performance.
6.5 In addition, Jardine Motors Group may use pixels or transparent GIF files, to help manage online advertising and/or email marketing.Any information that we collect and share through such means is anonymous and not personally identifiable.
6.6 Personal information will be retained by us and other members of Jardine Motors Group for as long as is reasonably necessary (or as defined under applicable laws and regulations) to provide products and services (including after sales service) to you and to maintain records as required to satisfy tax and other legal or regulatory requirements as well as to protect and defend against claims.
6.7 Jardine Motors Group may keep your details on record for as long as is necessary for the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.To determine the appropriate retention period for personal data set out above, Jardine Motors Group will consider 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.
6.8 We also collect technical data via Google Analytics.These reports are anonymised and so do not contain personal data.
6.9 We use a third party provider, Talkative Ltd, to supply our Live Chat service.We also use a third party provider, Call It Automotive Limited, to support our Talkative Live Chat service. Personal information that you volunteer to us via the Talkative Live Chat service may be shared with Call It Automotive for the legitimate business purpose of assisting with the handling of customer enquiries and follow ups.
7. Does Jardine Motors Group share personal information with third parties?
7.1 Your personal information will only be made available for the purposes mentioned above (or as otherwise notified to you from time to time) to staff who properly need to know these details for their functions within Jardine Motors Group.Please note that certain individuals who will see your personal information may not be based at Jardine Motors Group or within the United Kingdom (please see also clause 8 below).
7.2 We may disclose your personal information to other members of the Jardine Motors Group for any of the purposes set out above and those listed below.
7.3 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.In the event that you express an interest in a specific brand, especially in a particular make and model, and definitely if the interest is in a specific branded vehicle, make and model (such a 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.These manufacturers use your details independently from Jardine Motors Group and in accordance with their own privacy policies (details of which can be found on their websites).
7.4 Jardine Motors Group aims to ensure high quality and secure Personal Data used within the group.Where possible, the group wishes to do so in an efficient and uniform manner worldwide.To facilitate this, Jardine Motors Group has in place an Intra Group Agreement to identify and deal with the data protection and other relevant legal requirements involved in the sharing, transfer and other processing of Personal Data between the Jardine Motors Group companies. For further details of Jardine Motors Group, please visit www.jardinemotors.co.uk.
7.5 Each of the dealerships is operated by a company within Jardine Motors Group.When you place an order for product or service at a dealership, the data controller of the Personal Data will be the Jardine Motors Group Operating Company operating that local dealership. Lancaster plc may process that data on behalf of the dealership, including financial information, to process your order.Lancaster plc also provides other services to each dealership and processes your Personal Data in that context including processing and retaining Personal Data relating to your credit/debit card and order details to enable the fulfilment of your order and to deal with any queries or refunds of payment.
7.6 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 finance providers, marketing agencies, auditors, compliance managers, insurers, IT hosting, administration and IT maintenance providers (including those companies referred to in this notice).These companies may use information about you to perform their functions on our behalf.
7.8 The Website includes links to third party websites and some of your personal information from your browsing session may be transferred to such third party websites (please see our Cookies Policy https://www.jardinemotors.co.uk/site/nd-cookies-policy/ for more information).
8. Will your personal information be transferred abroad?
8.1 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.
8.2 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.As such, we will take reasonable steps to ensure that your personal information is adequately protected in accordance with the requirements of the UK data protection law.
8.3 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.
8.4 Please contact us by contacting our Customer Services Department at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. What choices does Jardine Motors Group offer you with regard to direct marketing?
9.1 Jardine Motors Group may wish to provide you with information about new 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 and our services. This communication may occur by e-mail, telephone call or message, post or text/SMS.We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.You may opt-out of direct marketing activities by contacting us as follows:
9.1.1 using the unsubscribe or opt-out links in marketing communications which we send to you;
9.1.2 contacting our Customer Services Department at email@example.com; or
9.1.3 writing to us at Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear, NE7 7EG.
9.2 This will allow you to opt out of telephone and email communications and/or to change previously submitted opt-out 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.
10. What safeguards are in place to protect your personal information?
10.1 While we take efforts to safeguard your personal information which are consistent with relevant laws, the nature of the internet is such that we cannot guarantee absolutely the security of any personal information you disclose online.
10.2 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.
10.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. What rights do you have to review and amend personal information?
11.1 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 by contacting our Customer Services Department at firstname.lastname@example.org.
- 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 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.
11.2 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 requirements of the GDPR with regard to your personal data.
11.3 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.
11.4 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.
11.5 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.
11.6 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.
12. Changes to this Policy
13. Contact/address details
Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear, NE7 7EG or alternatively by contact our Customer Services Department at email@example.com.