Steels Privacy Policy

Steels Westgate Ltd Privacy Policy (Last Updated April 2018)



The privacy and security of your personal information is extremely important to us. This privacy policy explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.  

We’ll keep this page updated to show you all the things we do with your personal data. This policy applies if you use any of our services, visit our website, use our mobile app, email, call or write to us. In certain circumstances we may also provide an extra privacy notice, which will always refer to this page.

We’ll never sell your personal data and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured.


1 Who are ‘we’?

1.1 In this policy, whenever you see the words ‘we’, ‘us’, ‘our’, ‘Steels Honda’ it refers to Steels Westgate Limited. (Our ICO registration number is Z7081220).

1.2 In this Privacy Policy, references to ‘you’ mean the person whose personal information (as defined below) we collect, use and process. This includes anyone who visits our Website, contacts us in connection with the purchase of a Vehicle and/or any goods or services we provide or otherwise interacts with us.

1.3 We are committed to protecting your privacy. We will use your personal information in accordance with the Data Protection Act 1998 up to and including 24 May 2018 and the EU General Data Protection Regulation 2016/679 thereafter (GDPR) (together the Data Protection Legislation). and other applicable laws and regulations that relate to data protection and privacy.

1.4 Steels Westgate Limited (Company Reg. No 1497000) is a motor dealership who holds a Honda franchise and supplies new Honda vehicles and used vehicles of all makes providing finance and insurance products from select companies. As well as this Steels also provide servicing, warranty, MOT, parts, repair and body shop work, and valeting.

1.5 If you have any questions in relation to this privacy policy or how we use your personal data they should be sent to dpo@steelshereford.com or addressed to the Data Protection Officer, Steels Westgate Limited, Steels Corner, Hereford, Herefordshire, HR4 0AP.


2 What information do we collect?

2.1 We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), vehicle details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). This information is referred to in this Privacy Policy as personal information. In particular, we may collect and process the following personal information about you:

Information that you provide by filling in forms, including those on our Websites.

A copy of your driving licence when you test drive a vehicle or are provided with a courtesy car.

When you enquire about or purchase a vehicle or services we collect personal information to respond to your enquiry and to process and complete your purchase.

Details about the transactions you carry out with us including vehicle support services and vehicle purchases and purchases of other goods.

Information contained in and records of communications between us, including e-mails, letters and text messages.

Details of your visits to our Websites, including, but not limited to, traffic data, location data (including the country and telephone area code where your computer is located), IP address and the resources that you access (including the pages of our Website that you view).

We will collect information concerning your marketing preferences.

We also collect information to enable third parties to carry out credit reference checks on you (if you are purchasing a vehicle on finance) and we will receive and process information about the outcome of those checks in order to complete your purchase.

We will collect information relevant to the insurance products that we sell that are provided by third parties.

2.2 If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.


3 How we use your personal information

3.1 Where you have provided consent we may use and process your personal information where you have consented for us to do so for the following purposes: 

to supply brochures and other material you have specifically requested from us;

to contact you via email, text message, post or telephone with marketing information about Steels Westgate Ltd and other products and services;

to share your personal information with our authorised dealers or our recommended third party partners for them to contact you with marketing information about their products and services.; and


3.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 10.1 for further details.

3.3 Where required to perform a contract with you we may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes:

To exchange information for warranty/aftersales;

To allow for the provision of third party breakdown services by our breakdown provider;

If you take 7 day free insurance cover via our insurance company (you will enter into a separate agreement for this)


3.4 Where it is in your vital interest we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
 


3.5 Where required to comply with our legal obligations we will use your personal information to comply with our legal obligations including: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.

3.6 Where there is a legitimate interest we may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;

for market research in order to continually improve the products and services that we and our authorised dealers deliver to you;

to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;

for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms;

for the prevention of fraud and other criminal activities;

to undertake credit checks for finance;

to correspond and communicate with you;

to create a better understanding of you as a customer or visitor;

for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;

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);

for the purposes of corporate restructure or reorganisation or sale of our business or assets;

for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;

to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and

for general administration including managing your queries, complaints, or claims, and to send service messages to you.



4 With whom do we share your personal information?

4.1 In connection with the above uses of your personal information, we may share your personal information with third parties as described below. We may disclose your personal information to third parties in connection with our business activities, including in the following circumstances:

4.2 We may pass your personal information to third party organisations that provide services to us (including assisting us with carrying out marketing activities).

4.3 We may pass personal information to external agencies and organisations (including the police and other law enforcement agencies) for the purpose of preventing and detecting fraud (including fraudulent transactions) and criminal activity. We may also disclose personal information to the police and other law enforcement agencies in connection with the prevention and detection of crime.

4.4 We may pass your personal information to a third party finance company for the purposes of them providing you with finance. Those organisations may carry out credit checks and may disclose your data to credit reference agencies for that purpose.

4.5 We will pass your personal information to third party providers of insurance products that we offer, if you take up the option of purchasing one of those products.

4.6 In the event that we sell or buy any business or assets (including car dealerships), we may disclose personal information held by us about our customers to the prospective seller or buyer of such business or assets. If we or substantially all of our assets are acquired by a third party (or subject to a reorganisation within our corporate group), personal information held by us about our customers will be one of the transferred assets.

4.7 We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us); or to protect our rights, property or safety or those of our customers, employees or other third parties;

4.8 We may pass your personal information to the relevant franchise manufacturer partner relating to your vehicle. They may contact you directly regarding your vehicle and to obtain feedback and/or to provide offers.

4.9 We may share non-personal aggregate statistics (group) data about visitors to our Websites, sales and traffic patterns with other parties.


5 Where we store your personal information outside the EEA
 

5.1 All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
 

5.2 If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
 

5.3 If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.



6 How long we keep your personal information for
 

6.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
 

6.2 We do not retain personal information in an identifiable format for longer than is necessary.


6.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in How we use your personal information in Section 4.
 

6.4 The only exceptions to this are where:
 

the law requires us to hold your personal information for a longer period, or delete it sooner;

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 in this section 7, or because we are required under the law (see further Erasing your personal information or restricting its processing in Section 8.6);
 

and in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.


7 Protecting your personal information

7.1 Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you.

7.2 The transmission of information via the internet is not completely secure; this risk is not specific to our Websites and is common across the internet. We cannot guarantee the security of your data (including your personal information) transmitted to our Website; any transmission is at your own risk.


8 What choices do you have?

8.1 If you think the personal information we hold about you is inaccurate or incorrect, you can request that we correct this information (including your marketing preferences) by writing to us using the details below.

8.2 You can choose to stop receiving marketing emails or SMS messages from us by following the unsubscribe link and instructions on the respective marketing emails or SMS messages we send you.

8.3 You can also choose to change your marketing preferences by writing to us using the details below.


9 Access to your personal information

9.1 The Data Protection Legislation gives you the right to access your personal information. To request access to your personal information, please contact us using the details below.


10 Right to be forgotten

10.1 You have the right to request that Steels Westgate Limited delete your personal data in certain circumstances if you would like more information about this please contact us using the details below.


11 Third Party sites

11.1 Our Websites contain links to other websites. This privacy policy applies only to our Websites, so visitors should always be aware when they are moving to another site and read the privacy statement of any site which collects personal information. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our Websites.

11.2 We do not pass on any personal information about our visitors to any other site (unless we have obtained your consent to do so). In addition, if you linked to a Website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site and contact the owner or operator if you have any concerns or questions.


12 Cookies

12.1 Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our Website.

12.2 The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site 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.

12.3 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.


13 How to contact us

13.1 If you have any questions, comments or requests regarding this Privacy Policy, please feel free to contact us by writing to us at: Data Protection Officer, Steels Westgate Limited, Steels Corner, Hereford, Herefordshire, HR4 0AP or emailing on dpo@steelshereford.com.