Howard Abraham Motors Ltd (“we”/”us”) shall comply at all times with the Data Protection Act 1998 or General Data Protection Regulation (Regulation (EU) 2016/679) 2106 (GDPR), and we are committed to protecting and respecting any personal information you share with us.
This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.
We will always give you the option not to receive marketing communications from us and our principal third parties. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. Refer to Appendix A for list of selected third parties that we work with.
The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.
What information do we collect?
We will collect information which is necessary, relevant and adequate for the purpose you are providing it, such as buying a car, applications and processing of credit, aftersales and other matters relevant to your enquiry. The information we collect includes some or all of the following:
Vehicle sales Lead Data
- Customer name (including title);
- Address;
- Phone number (including home/work/mobile)
- Email address;
- Model(s) of interest
- Gender
- Date of birth;
- Nature of enquiry
- Previous vehicle details (part-exchange)
- Customer contact preferences
- Voice recording of calls
Website enquiry Lead Data
- Customer name (including title);
- Phone number (including home/work/mobile)
- Email address;
- Model(s) of interest
- Nature of enquiry (parts, service or vehicles)
- Customer contact preferences
- Marketing preferences
Vehicle sales
- Customer name (including title);
- Address;
- Phone number (including home/work/mobile)
- Email address;
- Model(s) of interest
- Gender
- Date of birth;
- Nature of enquiry;
- Customer contact preferences;
- Previous vehicle details (part-exchange);
- Previous vehicle outstanding settlement information;
- Finance customers (personal information and proofs required by selected third party finance providers). The same shall be required for finance guarantors;
- Personal and vehicle information required to adopt additional products such as but not limited to Gap, Extended warranties, Service plans;
- Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details;
- Voice recordings of calls;
- Your marketing preferences;
- Methods of payment
- Finance renewals, to resolicit for repeat car sales and finance proposals. Data to include Name, identification number, address, phone number and email address.
Aftersales (parts and service)
- Customer name (including title);
- Customer address;
- Phone number (including home/work/mobile)
- Email address;
- Nature of enquiry (parts, service)
- Customer contact preferences
- Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information);
- The date and time you used our services;
- Voice recordings of calls;
- Any information within correspondence you send to us;
- Your marketing preferences;
- Methods of payment
How do we use this information?
We will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications or share your personal information with anyone else who might.
There are various ways in which we may use or process your personal information. We list these below:
Consent:
Where you have provided your consent, we may use and process your information to:
1. Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
2. To share your personal information with our principal third party partners, so that they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send information to them). You can withdraw your consent at any time by contacting us or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.
Contractual performance
We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us.
Legitimate Interests
We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
Processing necessary for us to support customers with sales, service, parts and other enquiries
1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: test drives, service and parts requests, brochure requests or information about specific vehicles, vehicle sales).
Processing necessary for us to respond to understanding customers’ and drivers’ needs
2. To analyse, evaluate and improve our products and services so that your visit to our showroom and use of our website are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);
3. 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. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraph above;
4. In some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications (for example, when your mileage suggests your vehicle is due for a service);
Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
5. To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry or requested a test drive, brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to unsubscribe to us sending you this information at any time;
6. 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;
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
7. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
8. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
9. 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);
10. To inform you of updates to our terms and conditions and policies.
Legal Obligation
We may process your personal information to comply with our legal and regulatory requirements (for example to register your car with the DVLA).
Vital Interest
Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.
How do we share this information?
We do not sell your information to third parties, but we do work closely with selected third party suppliers who fulfil business activities for us (like website hosting company(s), Gap, extended warranties, roadside assistance, marketing, events and market research etc.) Please refer to Appendix A for details of third party suppliers.
We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: roadside assistance service providers, customer contact centres, mobility and car hire providers, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.
We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets wherever possible. There may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
There are circumstances where we share your information in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested.
How long do we keep your information for?
We do not retain personal information in an identifiable format for longer than is necessary. If we have a relationship with you (e.g. you are a customer or the registered driver of a leased or other vehicle purchased from us, you have a credit account, are a service customer with us), we hold your personal information for 10 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the vehicle warranty or lease expires, or we have been made aware that you no longer own or drive that vehicle.
Where we have obtained your personal information following a request for information, test drive, brochure, quotation or any other information on any of our products or services, we hold your personal information for 2 years from the date we collect that information, unless during that period we form a relationship with you e.g. you purchase or lease a vehicle, complete a service or warranty event. We hold your personal information for this period to give us an opportunity to form a relationship with you.
The only exceptions to the periods mentioned above are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you);
How can we manage the information we hold about you
You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request.
You have the right to:
1) Ask for a copy of the information that we hold about you;
2) Correct and update your information;
3) Withdraw your consent (where we rely on it). Please see further How do we use this information;
4) Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5) Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
6) Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.
You can exercise the above rights and/or manage your information by contacting us using the details below:
Post: GDPR, Howard Abraham Motors, 55-93 Avenue Road, Lurgan, BT667BG
Appendix A - Third party suppliers
Other selected partners
For other third party partners to whom we pass your personal information as part of the legitimate conduct of your business with us, we shall NOT select your consent for marketing purposes, that is unless you advise otherwise.
Kia Assured Warranty (administered by Car Care Plan Ltd)
Bluecubes web design
Gap 1. TWG Services Ltd 2. Abraxas Insurance Administration Services
Textmagic Ltd.
ALD Automotive Ltd
Black Horse Finance
Cox Automotive
Artisan Web Solutions
Vital Software Ltd
The above list is not exhaustive and may be subject to change.
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